The use of international tax agreements (also known as tax treaties) to transfer corporate tax obligations to countries with lower tax rates is often referred to as “tax planning” or “tax optimization.” Here are some common ways： ### 1. **Establishment of a holding company** -**Purpose**: By setting up a holding company in a country or region with a lower tax rate, the profits are transferred to the holding company, so as to enjoy a lower tax rate. -**Implementation**: Companies can set up holding companies in low-tax countries (such as Ireland, the Netherlands, Luxembourg, etc.) and transfer profits to these companies through an equity structure. ### 2. **Use of intellectual property (IP) transfer** -**Purpose**: Transfer intellectual property rights (such as patents, trademarks, copyrights, etc.) to low-tax countries, and transfer profits to these countries through royalties, etc. -**Implementation**: An enterprise can set up an intellectual property holding company in a low-tax country, and authorize the intellectual property to other subsidiaries through a license agreement to collect royalties. ### 3. **Transfer pricing** -**Purpose**: To transfer profits to low-tax countries by adjusting the transaction prices between affiliated companies. -**Implementation**: Enterprises can transfer profits from high-tax countries to low-tax countries by adjusting the prices of goods, services, loans, etc. ### 4. **Take advantage of the preferential terms of tax treaties** -**Purpose**: To use the preferential clauses in tax treaties between different countries to reduce or avoid double taxation. -**Implementation**: Enterprises can use the tax relief clauses in the agreement to reduce their overall tax burden by setting up subsidiaries or branches in the agreed countries. ### 5. **Set up an intermediate company (Conduit Company)** -**Purpose**: To transfer profits to the final low-tax country by setting up an intermediate company in a country in the tax treaty network. -**Implementation**: An enterprise can set up an intermediate company in a country with tax treaties with multiple countries, through which profits are transferred to the final low-tax country. ### 6. **Use of offshore companies** -**Purpose**: To enjoy low tax rates or tax exemptions by setting up a company in an offshore financial center. -**Implementation**: Companies can set up companies in offshore financial centers such as the Cayman Islands, Bermuda, and the British Virgin Islands to transfer profits to these companies. ### 7. **Debt financing** -**Purpose**: By setting up subsidiaries in low-tax countries and transferring profits to these countries through debt financing. -**Implementation**: Enterprises can set up subsidiaries in low-tax countries and transfer profits to these subsidiaries through loans, etc., taking advantage of tax deductions for interest expenses. ### 8. **Use hybrid entities** -**Purpose**: Through the establishment of mixed entities (such as partnerships, trusts, etc.) in different countries, take advantage of the different classifications of entities in different countries to achieve tax optimization. -**Implementation**: Enterprises can set up mixed entities in different countries to take advantage of the differences in tax treatment of these entities in different countries to reduce the overall tax burden. ### 9. **Take advantage of tax deferral** -**Purpose**: To delay the payment of taxes in high-tax countries by setting up a subsidiary in a low-tax country and retaining profits in that subsidiary. -**Implementation**: An enterprise can set up a subsidiary in a low-tax country and keep the profits in that subsidiary until the profits are remitted to the parent company before paying taxes. ### 10. **Take advantage of tax exemptions** -**Purpose**: Use the tax exemption clause in the tax treaty to enjoy the tax deduction of taxes paid in low-tax countries in your own country. -**Implementation**: Enterprises can invest in low-tax countries and use tax exemption clauses to deduct taxes paid in low-tax countries in their home countries. ### Precautions： -**Compliance**: When companies conduct tax planning, they must ensure that they comply with the tax laws of various countries and avoid violating anti-tax avoidance rules (such as the BEPS Action Plan). -**Transparency**: With the improvement of international tax transparency, companies need to conduct tax planning more carefully to avoid being identified as tax avoidance. -**Professional advice**: It is recommended that companies seek the help of professional tax consultants and legal counsel when conducting complex international tax planning to ensure compliance and effectiveness. Through these channels, enterprises can optimize their tax structure within the legal scope and reduce their overall tax burden. However, it should be noted that with the continuous changes and strengthening of international tax rules, companies need to continue to pay attention to changes in relevant regulations and adjust their tax strategies.