Exactly. To put it even more explicitly, imagine that Google adwords system is solely created in the US. Now, Google wants to start selling ads in Spain. Should google.es pay anything for the IP underlying adwords? (I think they should; otherwise, there's a massive distortion in profitability and the US would cry foul that all the expenses are being borne in the US subsidiary and google.es is artificially highly profitable.)
Now, in order to manage that licensing activity (which can be very lucrative, but also requires specialized expertise and some risk), Google decides to set up a licensing division to manage all this.
In researching this, suppose they hypothesize that that IP labor and expertise is available in Ireland and decide to setup the IP licensing activity in Ireland. Google's Irish licensing division could negotiate a sub-licensable license from Google in US, then turn around and license it to Google (and perhaps other) companies around the world. Every player in that chain is creating value and it is perfectly proper for Google to create IP, to create a subsidiary to license that IP, and to license and deploy that IP in Spain; the question is "how much value did each entity contribute?"
Now, in order to manage that licensing activity (which can be very lucrative, but also requires specialized expertise and some risk), Google decides to set up a licensing division to manage all this.
In researching this, suppose they hypothesize that that IP labor and expertise is available in Ireland and decide to setup the IP licensing activity in Ireland. Google's Irish licensing division could negotiate a sub-licensable license from Google in US, then turn around and license it to Google (and perhaps other) companies around the world. Every player in that chain is creating value and it is perfectly proper for Google to create IP, to create a subsidiary to license that IP, and to license and deploy that IP in Spain; the question is "how much value did each entity contribute?"