The definition in a country-to-country 15. Having a subsidiary in a low-tax regime then own other subsidiaries has 1 point the advantage of: * Choose Transferring most revenue as royalty payments for intellectual property usage to the low-tax owner, reducing thereby taxes paid in other countries. Keeping the parent company's financial details safe from exposure in other countries Allowing investment in the target countries to come from a "more acceptable" source than the ultimate parent company's country