Yes I agree on this Zqq. However, this is what shelp-companies are often used for. Let's say your onshore company has valuable IP and you would like to transfer it to a offshore company. Wouldn't it cause suspicion if you would "sell" the IP for a nominal amount (e.g. 1 USD) to the offshore company at a time where the onshore company already generates hundreds of thousands dollars in revenue (also thanks to the IP). Wouldn't it be much more consistent if the IP was "sold" for a nominal amount at a time where the onshore company wasn't trading or just had very small revenue?
How else would you reasonably argue to the onshore tax inspector why you transferred/sold the IP for nominal amount (nominal because non-nominal you actually should be able to proof the bank-wire, which of course would be the cleanest but in practive just rarely happens)?