The following content is for academic discussion and general introduction only and cannot be regarded as legal, tax or accounting advice. When considering cross-border structures or tax planning, companies should always seek specific advice from professional advisors (such as certified public accountants, tax lawyers or other professionals) and ensure compliance with relevant regulations in various countries and regions (including transfer pricing rules, anti-tax avoidance regulations and international cooperation requirements such as BEPS). Generally speaking, companies may consider the following strategies to "move" intellectual property or other intangible assets to low-tax countries to optimize tax expenses: 1. Internal transfer or licensing of intellectual property • Transfer relevant assets to subsidiaries established in low-tax jurisdictions through internal transactions (for example, selling or licensing intellectual property within the group). • This approach usually adopts a market-based (arm's length) pricing method to comply with transfer pricing rules. • Background information such as the market value of the intellectual property, risk attribution and R&D investment needs to be reasonably explained. 2. Establishment of an intellectual property holding company (IP Holdco) • Establish a holding entity dedicated to holding intellectual property, usually registered in a country or region with a preferential tax system or intellectual property preferential policy (such as the "IP Box" system). • The holding company collects income through internal licensing or patent royalties, thereby optimizing the overall tax burden. • This approach requires attention to the supervision of licensing fees, royalties pricing requirements, and anti-abuse rules in various countries. 3. Cost Sharing Arrangements • For R&D investment and related intellectual property creation within the group, two or more parties can share R&D expenses to achieve a reasonable distribution of R&D results (and corresponding intellectual property) among various entities. • This arrangement must comply with the requirements of local tax authorities on cost sharing, risk sharing, and profit sharing to ensure that the overall arrangement complies with regulatory requirements. 4. Other structural arrangements • Some companies may adopt debt financing structures (such as loan arrangements) so that entities with high R&D and high intellectual property income are recorded in higher tax areas with lower profits, while receiving income in the name of the intellectual property holding company in low tax areas. • This arrangement is usually closely related to transfer pricing, internal financing and other issues, and requires careful layout and legal compliance review. • In addition, tax incentives in specific countries can also be explored, such as additional deductions for R&D investment and taxation of intellectual property income at a low tax rate. It is important to note that: • In recent years, cross-border tax planning arrangements have received great attention from tax authorities around the world (such as OECD anti-tax avoidance measures). Any attempt to transfer profits by constructing artificial transaction arrangements may face adjustment risks. • All of the above arrangements must meet the economic substance, market principles and business logic of specific transactions, otherwise they may be considered as tax evasion, resulting in additional penalties and adjustment risks. In short, although some of the above strategies are theoretically used by companies for tax planning, in reality each arrangement requires a detailed assessment of business, legal and tax compliance. It is recommended to have an in-depth discussion with professionals with cross-border tax and transfer pricing experience before making a structural arrangement, and pay close attention to the latest changes in international and domestic regulations.