Holding companies

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Holding companies

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

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

  1. migration or redomiciliation of an existing holding company to another country

  2. establishing an intermediate holding company through which to make an acquisition or through which to expand

  3. 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:

  1. where the company can realistically be managed and controlled, including where directors will be when decisions are taken

  2. withholding taxes and the double tax treaty relief available on distributions from subsidiaries, and whether relevant anti-abuse

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+™
Powered by Tolley+

Popular Articles

Loans provided to employees

Loans provided to employeesEmployers sometimes provide their employees with loans, sometimes charging interest and often not, either as part of the reward package or to help the individual meet significant expenditure. For example, it is common to provide loans for the purchase of annual travel

14 Jul 2020 12:11 | Produced by Tolley Read more Read more

Losses on shares set against income

Losses on shares set against incomeUsually, allowable capital losses can only be set against chargeable gains. If the losses are not fully utilised against gains in the year in which they arise, the excess is carried forward to use against future gains. See the Use of capital losses guidance note

14 Jul 2020 12:12 | Produced by Tolley Read more Read more

Enterprise management incentive schemes

Enterprise management incentive schemesWhat is an enterprise management incentive (EMI) scheme?The enterprise management incentive (EMI) scheme is a tax-advantaged share option employee incentive scheme aimed at small entrepreneurial companies that meet certain conditions. It is designed to assist

14 Jul 2020 11:36 | Produced by Tolley Read more Read more