Equity structure design is a complex process, especially when considering cross-border tax planning. While I cannot provide specific tax or legal advice, I can outline some common strategies. These strategies need to be carried out under the premise of complying with the laws of each relevant jurisdiction and require the involvement of professional legal and tax advisors: 1. **Holding company structure**: Establish a holding company in a tax-favored jurisdiction to hold the equity of other subsidiaries. The holding company can effectively manage earnings by taking advantage of the preferential tax rates of its location. 2. **Royalties and transfer pricing**: Place intellectual property (such as patents, trademarks) in a subsidiary in a low-tax jurisdiction, and then pay royalties from the high-tax jurisdiction to the subsidiary, thereby shifting part of the income. 3. **Profit shifting**: Through transfer pricing strategies, adjust the purchase and sales prices of subsidiaries within the multinational corporate group to shift profits to low-tax countries. This method must strictly comply with transfer pricing rules to avoid challenges from tax authorities. 4. **Financing strategy**: Use internal loan arrangements, and subsidiaries in high-tax jurisdictions pay interest to companies in low-tax jurisdictions to reduce public tax burdens. It should be noted that this path is also subject to relevant debt interest deduction restrictions. 5. **Use agreements to avoid double taxation**: Choose to set up structures in countries and regions that have signed double taxation agreements with the main operating areas and provide tax incentives. 6. **Tax incentive areas**: Some countries or regions provide specific tax incentives (such as free trade zones, special economic zones, etc.), and you can take advantage of the preferential policies of these regions on the basis of complying with local laws and regulations. It should be noted that although the above strategies may provide some help in tax planning, the tax laws of various countries are complex and changeable, and the international community has increasingly stringent scrutiny of the legality and compliance of these measures. Especially after the launch of the "BEPS" (Base Erosion and Profit Shifting) action plan, more countries and regions have begun to strengthen the control of tax losses. Therefore, when conducting global tax planning, it is important to ensure compliance and legality, and to obtain the support of professional lawyers and tax advisors.