Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
In any cross-border merger transaction an early issue to consider ought to be where the holding company for the merged group should be located. This is not just a tax question – the location of the business stock market requirements political concerns and practical issues for the management team all come into play – but tax can often be an important consideration.
As can be seen from the Tax Foundation’s recently published International Tax Competitiveness Index 2019 (see bit.ly/2nV67vx) there have been some significant developments in this area. For example the implementation of the Anti-Tax Avoidance Directives within the EU has eliminated some of the distinctions between EU member states such as whether they have transfer pricing rules or a controlled foreign company...
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Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
In any cross-border merger transaction an early issue to consider ought to be where the holding company for the merged group should be located. This is not just a tax question – the location of the business stock market requirements political concerns and practical issues for the management team all come into play – but tax can often be an important consideration.
As can be seen from the Tax Foundation’s recently published International Tax Competitiveness Index 2019 (see bit.ly/2nV67vx) there have been some significant developments in this area. For example the implementation of the Anti-Tax Avoidance Directives within the EU has eliminated some of the distinctions between EU member states such as whether they have transfer pricing rules or a controlled foreign company...
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:
