A multinational corporation has a successful subsidiary in a country that taxes cross-border dividend payments...

The company charges the subsidiary negotiated licensing fees on proprietary software.

The subsidiary sets up a re-invoicing center in another, tax-friendly country to manage a transfer pricing program.

The subsidiary lends funds to the parent. The loan is not repaid and the subsidiary writes it off.

Set up an in-house bank program at the successful subsidiary to make use of the excess liquidity in-country.