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. These tax issues will vary depending on the group’s particular circumstances and will often have to be considered in the round. The most common considerations are discussed in turn below.

Withholding tax

One of the most important tax issues when choosing the location of a holding company is

Continue reading the full document

To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™

TAKE A FREE TRIAL NOW

Popular Articles

Trusts and Inheritance Tax

Spouse exemption from inheritance tax

Spouse exemption from inheritance taxArguably, the most important inheritance tax exemption is the spouse exemption from inheritance tax.There is no IHT to pay on gifts from husband to wife and vice versa, or from one civil partner to the other (referred to collectively in this note as ‘spouses’).

14 Jul 2020 13:56 | Produced by Tolley in association with Emma Haley at Boodle Hatfield LLP Read more

Classes of NIC and who pays them

Classes of NIC and who pays themClass 1 NICClass 1 NIC is payable on earnings paid to an employed worker which derive from, or are treated as deriving from, an employed earner’s employment in the UK. There are two kinds of Class 1 NIC, primary contributions for which the employee is liable and

Owner-Managed Businesses

Interest on late paid tax

Interest on late paid taxIntroductionInterest on late paid tax is a compulsory charge set out in legislation to reflect the interest which would have accrued to the Exchequer had the correct amount of tax been paid at the right time.Harmonised legislation was introduced in 2009 to:•set statutory

14 Jul 2020 12:00 | Produced by Tolley in association with Philip Rutherford Read more

Holding companies

Holding companies