The UK as a holding company jurisdiction
Produced in partnership with Ben Jones and Colin Askew of Eversheds Sutherland (International) LLP
The UK as a holding company jurisdiction

The following Tax guidance note Produced in partnership with Ben Jones and Colin Askew of Eversheds Sutherland (International) LLP provides comprehensive and up to date legal information covering:

  • The UK as a holding company jurisdiction
  • Mitigation of local jurisdiction withholding tax on payments to a UK holding company
  • No or low tax on payments received by a UK holding company
  • Mitigation of UK withholding tax on payments by a UK holding company to shareholders
  • Other tax considerations
  • Complexity and instability of UK tax code
  • Engagement with UK tax authorities
  • UK tax incentive regimes
  • Taxation consideration on leaving the UK
  • Summary—UK as a holding company jurisdiction

This Practice Note focuses upon the attributes of the UK as a tax-efficient holding company jurisdiction and covers:

  1. withholding tax on payments to a UK holding company

  2. tax on payments received by UK holding company, including:

    1. corporation tax

    2. distributions exemptions

    3. substantial shareholding exemption

    4. carry forward of losses

    5. interest deductibility

    6. anti-avoidance rules, and

    7. diverted profits tax

  3. withholding tax on payments by a UK holding company to shareholders, including on:

    1. dividends

    2. interest and royalties, and

    3. management charges

  4. other tax considerations:

    1. value added tax (VAT)

    2. stamp duty

  5. complexity and instability of UK tax code

  6. engagement with UK tax authorities

  7. UK tax incentive regimes, and

  8. taxation considerations leaving the UK

Before undertaking any structuring of an international group of companies, the wider international tax context should also be considered. This includes:

  1. the Organisation for Economic Co-operation and Development's (OECD) ongoing initiative on Base Erosion and Profit Shifting (BEPS), upon which it published a fifteen point Action Plan in July 2013 and then published its first recommendations in September 2014 and its final recommendations in October 2015. Subsequently, various discussion drafts on specific actions have been published. For further details on the BEPS action plans (including legislation enacted or proposed to be enacted in the UK), see: Tax—Base Erosion and Profit Shifting tracker, and

  2. the impact of the UK leaving the EU (Brexit), especially where specific EU

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