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

Personal Tax

Taxation of dividend income

Taxation of dividend incomeIntroductionA dividend is a distribution of profit by a company to its shareholders.A dividend is not only a payment in cash. It can be the issue of new shares in exchange for forfeiting the right to a cash payment (a stock dividend). For more detail, see the Cash

14 Jul 2020 13:48 | Produced by Tolley Read more

Owner-Managed Businesses

First year allowances

First year allowancesFirst year allowances (FYAs) are available on the following items:•first-year relief on qualifying new main rate plant and machinery (at 100%, which is described by HMRC as ‘full expensing’) and special rate assets (at 50%) from 1 April 2023 (companies only). These FYAs were

14 Jul 2020 11:41 | Produced by Tolley Read more

Autumn Budget 2025

Corporation Tax

Terminal trading loss relief

Terminal trading loss reliefTerminal loss relief for trade losses in the final 12 monthsTrading losses incurred by a company in the final 12 months leading up to the discontinuance of trade may be carried back for up to three years from the period beginning immediately before that 12-month period.

14 Jul 2020 13:49 | Produced by Tolley Read more

Holding companies

Holding companies