ISIN - First 2 Letters : Issuing Country vs Domicile Country

I have a question regarding how the logic in the ISIN structure work for the first 2 letters.

It is mentioned the following : The first two characters are the alpha-2 country code, in accordance with the international standard ISO 3166, of the NNA that assigned the code or the country of the security issuer, depending on whether it is debt, equity, warrants, etc., in accordance with the ISO 6166 standard.

Can be the issuer country and the tax domicile of the country different?

This is one example : Alibaba – US01609W1027. The ISIN country is US (issuer country is US) but the tax domicile of the company is Cayman Islands.

I guess in most of the cases the issuer country is the same as the tax domicile but there are some exceptions.

Is this information correct?

Thank you,

Kat