The main task addressed by the creation of a foreign holding company is enabling the holding of assets on a centralized and confidential basis in the legal framework of another country. In addition, the application of international double taxation treaties to a holding company enables it to reduce its tax burden when repatriating dividends.
Currently, international tax planning practices offer a number of jurisdictions that, subject to specific conditions, allow the incorporation of holding companies that compare favorably in terms of tax preferences. The Republic of Cyprus is a popular solution to this problem. As tax residents of the European Union, such companies are exempt from income taxes on dividends, capital gains and financial instruments.
In addition to the Republic of Cyprus, favorable tax treatments to create effective holding entities are also offered by Singapore, Hong Kong, the Netherlands, Austria, Luxembourg and the United Kingdom. The participation of companies domiciled in these countries in holding chains gives rise a higher reputational rating for the group and entails higher costs to implement the structure.
Lawson&Wang's professionals will be happy to go through the option you select in detail to verify whether it is consistent with tax laws up to arbitration practice and description of tax risks and model several options of the required structure with a description of tax implications within a consulting project.