Sentence:  The ability to shift profits to low-tax countries by locating intellectual property in them...is often assumed to be the preserve of high-tech companies....current tax rules make it easy for all sorts of firms to generate...“stateless income”: profit subject to tax in a jurisdiction that is neither the location of the <WSD>factors</WSD> of production that generate the income nor where the parent firm is domiciled. 
Meaning of the word marked with <WSD> tags:  A resource used in the production of goods or services, a factor of production.