How do you realize anything without being able to send an invoice and collect?
The challenge is if someone makes a software company, and a team of 20 workers on computers create a €10B business, does the state have a fair claim to €5B of it when the company at most with the most generous possible estimate (and then double it for good measure) used €50M of state services?
Yes, it does. Quite simply because that's the law, and it's morally right (in principle) because if your business fails then you don't get a bill for 50 million. If "winners" only paid their exact share then these services wouldn't exist.
So $50m would cover their true societal cost (I'll multiply it by 10 for you, call it $5m) 10x over.
Its extremely difficult to build a clearly logical structure where a company that made a wildly successful product needs to hand half the value to the government. It's very easy to do if we hand wave with ambiguous terms like "right thing to do" and "morally obligated".
Selling a company and paying tax on the profit in tax is a completely different proposition from paying tax on hypothetical profit you haven't made (and might never make) just because you want to move.