The holding company is in a country that pays little to no corporate income tax and it owns all the IP that the company that makes the product. e.g. I make phones and I have copyrighted software and a patent on a fingerprint sensor that’s under the screen. After paying for labor and materials I have $1,000,000 left over, but since a holding company actually owns the IP, they charge me a $900,000 licensing fee to use it. I only have to pay corporate income tax on $100,000 now, not $1,000,000.
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