Say a US company's French subsidiary sold something for $10 in France. If the software is developed in the US, then the US company will sell it to the French subsidiary for $9, so then they only have pay profits on $1 in France. Then in the US, they will say they paid $3 in costs and sold the software to their French counterpart for $9, booking $6 of profits in the US at a lower rate.
Say a US company's French subsidiary sold something for $10 in France. If the software is developed in the US, then the US company will sell it to the French subsidiary for $9, so then they only have pay profits on $1 in France. Then in the US, they will say they paid $3 in costs and sold the software to their French counterpart for $9, booking $6 of profits in the US at a lower rate.