Multinational companies carry out tax planning through complex equity structures, and they need to operate under the premise of legal compliance. The following are common international tax optimization methods and potential risk analysis for academic research reference： --- ###**1. Design model of core equity structure** 1. **Offshore holding company structure** -Set up intermediate holding companies in income tax-free areas such as the Cayman Islands and the BVI to pool profits through equity transfer and dividend distribution. -Technical points: it is necessary to meet the "economic substance" requirements of the location of the holding company (such as the avoidance of the EU blacklist). 2. **Regional headquarters Center (Regional HQ)** -Set up regional headquarters in low-tax regions such as Singapore and Ireland to centrally manage business in the Asia-Pacific or European regions. -Case study: A technology company licenses intellectual property rights to an Irish subsidiary and transfers profits through royalties (tax rate of 12.5%). --- ###**2. Technical path of profit transfer** 1. **Transfer Pricing (Transfer Pricing)** -Adjusting the profit distribution through intra-group transactions (goods/services/financing) must comply with the "Arm's Length Principle" stipulated by the OECD. -Risk: Tax authorities in various countries have tightened their scrutiny of related-party transactions. For example, China's anti-avoidance cases in 2017 recovered 840 million yuan in taxes. 2. **Intellectual property (IP) licensing structure** -Set up an IP holding entity in a low-tax area to transfer profits by collecting royalties. -Compliance requirements: It is necessary to prove that the IP ownership matches the place of value creation (BEPS Action Plan 8-10). 3. **Supply chain reorganization** -Allocate high value-added links (such as R&D and marketing) in low-tax areas, and distribute profits through cost-sharing agreements (CSA). --- ###**3. Key points of tax risk control** 1. **Response to anti-tax avoidance regulations** -Controlled Foreign Company (CFC) rules: Article 45 of China's Corporate Income Tax Law may treat offshore undistributed profits as dividends and tax them. -Capital weakening restrictions: Interest expenses whose debt/equity ratio exceeds the statutory standard (such as 2:1) shall not be deducted before tax. 2. **Economic Substance Act (E.G. BVI, Cayman)** -Offshore companies need to maintain substantial operations such as office premises and employees locally, otherwise they face the risk of cancellation. 3. **The world's lowest tax (GloBE Rules)** -The OECD's 15% global minimum tax rate (Pillar 2) will be implemented from 2024, and companies with an annual income of more than 750 million euros will be affected. --- ###**4. Compliance recommendations** 1. **Document preparation** -Prepare the Master File, Local File, and country report (CbCr) to prove the rationality of transaction pricing. 2. **Advance Pricing Arrangement (APA)** -Reach a pre-pricing agreement with the tax authorities to reduce the risk of audit (such as the bilateral APA case between China and the United States). 3. **Dynamic monitoring** -Use tax automation systems (such as Thomson Reuters ONESOURCE) to track changes in national regulations in real time. --- ###**5. Data reference** -According to an IMF study, the average annual tax loss of multinational companies in developing countries through profit transfer exceeds 200 billion U.S. dollars. -Statistics from the European Commission show that the number of cross-border tax disputes rose by 37% year-on-year in 2019. --- **Conclusion**: International tax planning needs to balance business substance and compliance requirements. It is recommended that enterprises establish a three-tier defense strategy (legal compliance layer, operational substance layer, and dispute resolution layer), and conduct a full-process risk assessment through professional institutions. In the current environment, the tax benefits of relying solely on offshore structures have been significantly reduced, and the future trend will shift to the rational distribution of the value chain and the adaptation of tax rules in the digital economy.