Arranging corporate income in tax-lenient jurisdictions through complex equity structure design to minimize global tax burden is a complex and professional tax planning field, and in actual operation, it is necessary to strictly abide by the laws and regulations of various countries to avoid tax risks and legal issues. The following is a general framework of ideas, but please note that the specific implementation requires professional tax consultants to plan and operate in detail according to the actual situation of the enterprise: ### Basic principles 1. **Legal and compliant**: Ensure that all structural designs and tax arrangements are in full compliance with the tax laws of various countries and relevant international tax rules to avoid any form of tax evasion. 2. **Substantial business activities**: Although the purpose is to optimize the tax burden, it is not possible to over-fabricate the business or transfer the business substance just for tax benefits. The structure should have a certain commercial rationality. ### Common structural design steps 1. **Establish a holding company** - Establish a holding company in a low-tax or tax-favorable region. For example, Ireland, the Netherlands, Singapore, etc., these regions usually give preferential tax policies to overseas dividend income, and may even provide tax exemption treatment. - The parent company of the corporate group gradually transfers its equity in various operating entities to the holding company, making the holding company the equity control center of the entire group. 2. **Building a multi-layered equity structure** - Establishing a number of special purpose vehicles (SPVs) above or in parallel with the holding company to form a multi-layered equity structure. These special purpose vehicles can further refine their functions, such as regional operating companies, intellectual property holding companies, etc. - Through a multi-layered structure, equity and profit distribution can be managed more flexibly, while taking advantage of tax treaties and legal differences between different jurisdictions. 3. **Utilizing intellectual property and intangible assets** - Transferring the company's core intellectual property, such as patents, trademarks, and know-how, to subsidiaries or special purpose vehicles in low-tax jurisdictions. - Transferring profits from high-tax regions to low-tax regions holding intellectual property by charging intellectual property licensing fees to other operating entities, because intellectual property-related income may be subject to lower tax rates in some regions, or may enjoy special tax incentives. 4. **Profit transfer and pricing strategy** - Transferring profits from operating entities in high-tax regions to related companies in low-tax regions through related-party transactions, such as raw material procurement, product sales, and service provision. - Adopting transfer pricing strategies to reasonably determine the prices of related-party transactions. For example, the production of high value-added products can be arranged in low-tax regions, and more profits can be retained in the region through internal pricing. However, transfer pricing must comply with the arm's length principle, otherwise it may face adjustments by the tax authorities. 5. **Utilize tax treaties** - Study and utilize tax treaties signed between different countries. For example, some tax treaties may have preferential tax rates for withholding taxes on income such as dividends, interest, and royalties. - By reasonably arranging the equity structure and transaction model, enterprises can fully enjoy the benefits brought by tax treaties and reduce the tax burden in cross-border transactions. ### Considerations in actual operations 1. **Anti-tax avoidance regulations**: All countries are strengthening anti-tax avoidance efforts, and enterprises need to pay close attention and ensure that the structure design will not be identified as an abuse of tax incentives or malicious tax planning. For example, the Base Erosion and Profit Shifting (BEPS) Action Plan issued by the Organization for Economic Cooperation and Development (OECD) has a profound impact on global anti-tax avoidance rules, and enterprises should follow relevant standards. 2. **Information disclosure requirements**: Some countries require enterprises to disclose information such as their cross-border transactions and equity structures to prevent tax losses. Enterprises need to disclose information in a timely and accurate manner in accordance with regulations to avoid fines or other penalties due to violations. 3. **Business risks**: An overly complex equity structure may bring additional management costs and business risks, such as reduced decision-making efficiency and difficulties in operational coordination. Enterprises need to find a balance between tax optimization and business operations to ensure that structural adjustments will not have a negative impact on the normal operation of the enterprise. In short, minimizing global tax burdens through complex equity structure design is a highly complex and personalized process that requires comprehensive consideration of many factors and careful planning and implementation by a professional team of tax, legal and financial experts. At the same time, enterprises should always take legality and compliance as the primary principle to avoid serious legal consequences and reputation losses caused by improper tax planning.