No — it depends on profit repatriation, loss offsetting, and exit scenarios. The decision should be made by looking at the ten-year cash flow, not a single rate.
The non-tax consequences often decide it. A branch has no separate legal personality, so the head office bears its liabilities directly and profit repatriation can carry its own tax cost; a subsidiary ring-fences liability and can open up treaty and participation benefits. That is why the ten-year view has to weigh structure and liability, not just the headline rate.
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