Tesco is run for the benefit of its shareholders. The benefit it provides to them is solely in the form of current and future dividends. All dividends have to be paid out of the UK parent company. The only way money earned abroad can reach the UK parent company is if it is paid as a dividend from the foreign subsidiary [*]. All dividends from foreign subsidiaries paid to the UK parent company are taxed at standard UK corporation rate, irrespective of the events abroad that allowed Tesco to make the money [**].

So can you explain how, exactly, it is possible for Tesco to use this structure to cheat the UK taxman out of sizeable amounts of money?

(I've a blogpost here making a similar point)

[*] or through transfer pricing, but that can only ever work to avoid tax in the subsidary's country not in the parent company's country

[**] except that if it can show it has paid foreign tax on the money, that will be offset against its UK tax liability