Allan Cinnamon and Nick Udal provide a detailed comparison of tax issues for holding companies in key jurisdictions
The incorporation of a foreign holding company to own foreign subsidiaries is still a common strategy for groups operating internationally despite participation exemptions at home such as the UK’s Foreign Distribution and Substantial Shareholding Exemptions. Often this strategy is driven by commercial rather than tax factors. But in addition holding companies can provide a wide range of tax benefits including improved access to tax treaties tax-free reinvestment of profits and tax-free disposals. To assist with selection of the appropriate jurisdiction the table in this article provides a comparative summary of the tax considerations relevant to a number of representative jurisdictions.
For many years the Netherlands was the most-favoured jurisdiction. But subsequently with the convergence of corporate tax rates the requirements of the Parent Subsidiary Directive...
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Allan Cinnamon and Nick Udal provide a detailed comparison of tax issues for holding companies in key jurisdictions
The incorporation of a foreign holding company to own foreign subsidiaries is still a common strategy for groups operating internationally despite participation exemptions at home such as the UK’s Foreign Distribution and Substantial Shareholding Exemptions. Often this strategy is driven by commercial rather than tax factors. But in addition holding companies can provide a wide range of tax benefits including improved access to tax treaties tax-free reinvestment of profits and tax-free disposals. To assist with selection of the appropriate jurisdiction the table in this article provides a comparative summary of the tax considerations relevant to a number of representative jurisdictions.
For many years the Netherlands was the most-favoured jurisdiction. But subsequently with the convergence of corporate tax rates the requirements of the Parent Subsidiary Directive...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
