The regulation knee-jerk statement "ensure that all profits are duly taxed in the country where the productive and commercial activities take place" avoids one vital piece of information:
If goods are manufactured in a company's home factories (say, in Europe) and the exported to another country (say, in Africa) for sale by a subsidiary company of the manufacturer, how is the profit to be divided "for taxation purposes"?  
Two figures can be established without much dispute: the cost of production, (for these purposes including "overheads" such as transport costs and any customs duties payable), and the actual selling price.  The difference between these is then the ("bottom-line") nett profit.  How is this to be divided for taxation purposes between the two countries involved?  At best, the division is arbitrary, and the subject of immense debate.