Excluding VAT, the tax should have been 28.5 USD and they have managed to pay 3.3 USD. This is a very basic example and figures are probably far from accurate, but you get the idea. A solution has to address this pick and choose of where to pay.
I have a far better solution. Why not change the tax in all countries to that of Ireland?
Doesn't it make far more sense, companies would not have to go through all this, you won't have a lot of guys chasing them down and products would be much cheaper for everyone ? Of course, the governments would have to cut their spending and they will not have that much leverage when trying to bribe voters with claims that they are fighting the evil corporations and they are spending all their blood on these battles, but I could live with that.
As you mentioned, I think the biggest problem with this agreement is to exacerbate the imbalance between developed and developing countries.
~
Obviously, the developed countries get more profits, while the manufacturing-based developing countries can only get a small return. I think it will also accentuate the inequalities between rich and poor countries.
You're looking at it from the wrong point of view.
If there would be no rich countries to pay 250$ for that phone the poor manufacturing countries would be out of a job!
Try to sell that for 200$ right from the factory and let's see what happens, in one month the factory is in another country.