XYZ Corporation, a multinational company based in the United States, is planning to expand its operations into several European countries. The company is considering two options for the structure of its overseas operations: establishing subsidiaries in each country or creating a single European holding company to manage all its European assets. Discuss the tax implications of each option, taking into account the potential benefits and risks associated with transfer pricing, tax credits, and double taxation treaties. Additionally, evaluate how changes in international tax law, such as the OECD's Base Erosion and Profit Shifting $($BEPS$)$ initiatives, might impact XYZ Corporation's decision.