Holding companies

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

There are a number of occasions when it is necessary to consider the location for a holding company, including:

•
migration or redomiciliation of an existing holding company to another country
•
establishing an intermediate holding company through which to make an acquisition or through which to expand
•
establishing a new holding company to act as a listing vehicle

An attractive location for a holding company from a tax perspective will be one which minimises the tax on income and gains generated by the group. This will depend in part on the location of the group’s subsidiaries and the location of its shareholders.

Tax issues when choosing a holding company location

There are several tax issues to consider when deciding where to establish the holding company of the group.

In practice, the following factors often determine the holding company location:

•
where the company can realistically be managed and controlled, including where directors will be when decisions are taken
•
withholding taxes and the double tax treaty relief available on distributions from subsidiaries, and whether relevant anti-abuse

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