Test the ability to analyze and recommend tax-efficient capital structures and cross-border financing strategies for multinational firms operating under differing international tax regimes and transfer pricing rules. Evaluate trade-offs between debt, equity, and hybrid instruments; apply thin-capitalization and interest limitation rules, withholding tax and treaty issues, CFC/GILTI and BEPS implications; price intercompany loans and services under arm's-length principles; quantify tax and cash-flow impacts in case-based scenarios; and identify compliance, documentation, and risk-management considerations to justify recommended structures.