Practice guide: Establishing a holding company

Introduction

There are a number of occasions when a multinational group must consider the best location for a holding company including:
 
      ●     migration or redomiciliation of an existing holding company to another jurisdiction;
     
      ●     establishing a subholding company through which to make an acquisition or through which to expand;
     
      ●     establishing a new holding company to act as a listing vehicle.

The best location from a tax perspective will be one which minimises the tax on income and gains generated by the group and therefore the return to shareholders.

This will in turn depend largely on the location of the group's subsidiaries and the location of its shareholders.

Tax considerations

The desirable features for a holding company from a tax perspective are typically the following:
  
      ●     low...