# Global Tax planning and Corporate structure Design Understanding your concern about tax planning, I can provide some general information about international tax planning. Please note that tax planning should be carried out within the framework of legal compliance. ## Basic principles of legal tax planning -**Substantive requirements**: The modern tax system requires that business arrangements must have real business substance, not just for tax avoidance purposes. -**Transparency**: The global exchange of tax information (such as the OECD's CRS) and the reporting requirements of multinational companies make it more and more difficult to avoid pure tax. -**Economic substance**: Many low-tax jurisdictions have implemented economic substance regulations that require companies to have actual operations in the local area. ## Common international tax structure design considerations 1. **Holding company structure**: Set up a holding company in a country/region with a well-established tax treaty network 2. **Intellectual property planning**: Concentrate intellectual property rights in innovation-friendly tax jurisdictions, but comply with BEPS transfer pricing rules 3. **Optimization of financing structure**: Consider the balance of debt and equity, and pay attention to the capital weakening rules of various countries 4. **Function and risk allocation**: Reasonable allocation of functions and risks according to the enterprise value chain ## Modern tax Challenges -The OECD's "Base Erosion and Profit Shifting" (BEPS) Action Plan severely restricts aggressive tax avoidance arrangements -The world's lowest tax rate (such as the OECD's 15% minimum tax rate plan) is being implemented -Increasingly stringent anti-tax avoidance regulations in various countries It is recommended that you consult a professional tax consultant to formulate a compliance tax strategy based on your specific business situation, while considering various factors such as business needs, compliance requirements, and operational efficiency.