Entity Structuring for Cross-Border Expansion: Avoiding Pillar II Pitfalls
As companies expand internationally, entity structuring becomes more than a compliance decision—it becomes a strategy for growth, risk mitigation, and global tax efficiency.
Under the OECD’s Pillar II framework, foreign affiliates earning less than a 15% effective tax rate may expose the parent company to top-up taxes. Improper structuring can lead to double taxation or tax inefficiency.
