Multinationals have available to them a wide choice of locations in which to base a foreign holding company. The main potential tax advantages to be derived are the minimisation of taxes on dividends and gains realised from foreign operating subsidiaries. The table in this article aims to collate the facts that will assist in making a decision and to provide a yardstick for comparison of salient features. The final choice of location will be governed by the nature and location of the operating subsidiaries, the business location and profile of the group, and home and source country anti-avoidance rules.
