How to choose a holding company jurisdiction—tax considerations
Produced in partnership with Andrew Howard of Ropes & Gray
How to choose a holding company jurisdiction—tax considerations

The following Tax practice note produced in partnership with Andrew Howard of Ropes & Gray provides comprehensive and up to date legal information covering:

  • How to choose a holding company jurisdiction—tax considerations
  • An introduction to holding companies
  • Key attributes of a tax-efficient holding company
  • Mitigation of local jurisdiction tax on payments to holding company
  • No or low tax on payments received by the holding company
  • Mitigation of holding jurisdiction tax on payments from holding company to shareholders
  • Other relevant tax attributes
  • Checklist—key tax attributes of a holding company jurisdiction

How to choose a holding company jurisdiction—tax considerations

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for Tax?

An introduction to holding companies

For businesses expanding internationally, or funds and other entities making international acquisitions, an important consideration is the corporate holding structure for the business and the location of the entities used to own and operate the expanding business.

Many commercial factors are relevant to this issue, including the nature of the business and its customer base, the location of key management and employees and access to finance and other support services, but taxation and tax efficiency is often also an important consideration.

From a tax perspective, the main objective for the holding structure of an international business is typically to minimise tax leakage on the distribution of profits and gains to shareholders and other beneficiaries. The location of the underlying business activities and the ultimate shareholders will usually be fixed but there is

Popular documents