# Tax planning considerations for repricing of intellectual property rights and migration across jurisdictions When considering the migration of intellectual property rights to low-tax jurisdictions, it is necessary to carefully balance legal tax planning with compliance with international tax laws. The following are the key considerations： ## Main strategy： 1. **Establish a substantial business presence** -Set up a R&D center or management organization with actual business substance in a low-tax area - Ensure that there are sufficient employees, equipment and decision-making authority 2. **Comply with transfer pricing rules** -Adopt the principle of independent trading to determine the fair market value of intellectual property rights -Prepare comprehensive transfer pricing documents to support pricing decisions 3. **Phased implementation** -Gradual migration of intellectual property rights through royalty agreements -Establish a cost-sharing agreement to jointly develop new intellectual property rights ##Compliance requirements to be considered： -Requirements of the OECD BEPS (Base Erosion and Profit Shifting) Action Plan -Anti-avoidance rules of various countries (such as CFC rules, general anti-avoidance clauses) -Economic substance requirements and beneficial ownership regulations Professional tax consultants should be consulted to ensure that the plan complies with the tax laws of relevant countries and avoids being identified as aggressive tax avoidance. Tax authorities are increasingly concerned about the economic substance and commercial rationality of such arrangements.