This seems entirely reasonable. Suppose you're a company and you lost $100m over the last few years, so naturally you have a sizable tax deduction from future earnings. Even if you're profitable now, over the life of your business you've lost money so it makes sense you don't pay taxes until you make back that $100m you lost.
If you begin selling in a different tax jurisdiction, that would be unfair that you have to start paying corporate taxes despite being unprofitable. It's not a brand new company and you're using the resources you built in the other country so royalty and licensing fee make sense. In other words, Starbucks brand name and operational efficiencies are assets that were developed in the US, so the US subsidiary should receive revenue from the service to the UK branch
If you begin selling in a different tax jurisdiction, that would be unfair that you have to start paying corporate taxes despite being unprofitable. It's not a brand new company and you're using the resources you built in the other country so royalty and licensing fee make sense. In other words, Starbucks brand name and operational efficiencies are assets that were developed in the US, so the US subsidiary should receive revenue from the service to the UK branch