Holding companies

By Tolley in association with Robert Langston of Saffery Champness

The following Corporation Tax guidance note by Tolley in association with Robert Langston of Saffery Champness provides comprehensive and up to date tax information covering:

Holding companies
Introduction
Tax considerations
Double tax agreements
Commercial factors
Shareholder tax issues
Further reading

Introduction

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 a subholding 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 considerations

The UK offers some of the features which may be attractive for a holding company. These features typically include: