Using international tax agreements to optimize corporate tax structures is a common practice in global operations, aiming to achieve effective management of tax burdens while complying with the laws of each country. The following are some common legal ways that companies can consider under the guidance of professional tax advisors: 1. **Choose a favorable place of registration**: - **Low-tax countries or regions**: Some countries or regions offer lower corporate income tax rates or tax incentives, where companies can set up subsidiaries or holding companies, such as Ireland, the Netherlands, Singapore or the Cayman Islands. - **Tax havens**: Although these regions are known for their low tax rates, companies must ensure the substance of their operations and transactions to avoid triggering anti-tax avoidance regulations. 2. **Use double taxation agreements (DTAs)**: - **Avoid double taxation**: By signing double taxation agreements between countries, companies can avoid double taxation of the same income in two countries. - **Tax incentives**: Some agreements may provide lower withholding tax rates for cross-border payments such as dividends, interest and royalties. 3. **Transfer Pricing**: - **Reasonable pricing of internal transactions**: When transferring goods, services or intellectual property between related companies, ensure that the pricing complies with the "arm's length principle" to reflect market prices and optimize the overall tax burden. - **Documentation and Compliance**: Ensure that all transfer pricing arrangements are fully documented and comply with the tax laws of the relevant countries to avoid potential tax disputes. 4. **Establishing a holding company or parent company**: - **Centralized management of income**: Tax optimization may be achieved by establishing a holding company in a tax-friendly country to centrally manage the profit distribution of global subsidiaries. - **Capital gains incentives**: Some countries provide tax exemptions or reductions for capital gains from cross-border equity transfers. 5. **Intellectual Property (IP) Strategy**: - **IP holding company**: Establishing an IP holding company in a low-tax country allows royalties and license fees from around the world to be taxed there, thereby reducing the overall tax burden. - **R&D expense allocation**: Reasonably allocate R&D-related expenses and income to optimize tax effects. 6. **Tax incentives and preferential policies**: - **R&D tax credit**: Some countries provide tax credits or exemptions for R&D activities to encourage enterprises to carry out innovation activities locally. - **Investment incentives**: Certain regions may provide preferential policies such as tax exemptions, tax holidays, etc. to foreign-invested enterprises. 7. **Structural optimization and restructuring**: - **Business structure adjustment**: Improve tax efficiency by optimizing the business structure of the enterprise, such as mergers, spin-offs or restructuring. - **Debt financing structure**: Optimize interest deductions and capital structure through reasonable debt and equity financing structures to achieve tax optimization effects. **Important tips**: - **Compliance**: Any tax optimization strategy must be carried out within the framework of national laws and international tax agreements to avoid violating anti-tax avoidance regulations or being deemed as illegal tax evasion. - **Professional consultation**: Tax planning is complex and involves the laws of multiple countries. It is recommended that enterprises consult professional tax advisors or legal experts before implementing any international tax strategy to ensure legal compliance and maximize tax benefits. Through legal and compliant tax planning, enterprises can not only optimize their tax burden, but also enhance their competitiveness in the international market.