Structure de Holding

• 0% tax on incoming dividends

The exemption from corporate tax on dividends received from subsidiaries is available in many European jurisdictions.

Cyprus, Latvia, Netherlands, Malta, Hungary

• 0% tax on outgoing dividends

0% withholding tax on outgoing dividends paid by the holding company to shareholders (non-resident or non-resident individuals).

Cyprus, Hong Kong, Latvia, Singapore, Ireland, Hungary

• Confidentiality of the actual beneficiary

Offshore companies, trusts and foundations are often used for this purpose. Prestigious European jurisdictions may establish confidential trust companies for inheritance and non-disclosure purposes

Austrian and Irish Family Fund, or Dutch STAK . Contact us for more details

• 0% capital gains tax on the sale of shares

Capital gains tax on the sale of shares is exempt in many European jurisdictions.

Cyprus, Latvia, Netherlands, Malta, Hungary

 

In order to apply double taxation treaties or the EU directive on parent subsidiaries to lower or eliminate the dividend tax, the holding company must:

• be a tax resident corporation (must be able to present a tax resident certificate)
• comply with the requirements of the participation exemption (if any) imposed by the
• minimum ownership period
• minimum percentage of shares on the property
• level of corporate income tax in the subsidiary's jurisdiction (tax test)

 

	Incoming dividends	Outgoing dividends
Latvia	0% corporate tax Received by a Latvian company from resident and non-resident companies (excluding offshore companies).	0% 0% personal allowance for non-resident corporate shareholders 0% for resident corporate shareholders 10% for individuals
Cyprus	0% corporate tax if min. 50% of subsidiary income is commercial income, and the subsidiary is subject to at least 5% tax in its own jurisdiction.	0% 0% personal allowance for non-resident corporate shareholders 0% for resident corporate shareholders 0% for individuals
Netherlands	0% corporate tax Under the terms of the participation exemption: The Dutch holding company owns at least 5% of the shares of the subsidiary; The subsidiary is a trading company or a subsidiary is not held as a portfolio investment; The subsidiary is subject to a "tax test" – a minimum tax rate of 10% on companies; The subsidiary is subject to an "asset test" – passive assets must be less than 50%.	Withholding 0% at source under the EU Parent Subsidiaries Directive and/or The participation exemption applies. 15% in other cases, but structuring is possible.
Singapore	0% corporate tax If dividends come from the jurisdiction with a minimum of 15% corporate tax.	0% furniture allowance 0% for non-resident corporate shareholders 0% for resident corporate shareholders 0% for individuals
Malta	0% corporate tax If the Maltese company owns at least 10% of the shares of foreign companies; OR has investments in a subsidiary for a minimum amount of 1.5 million euros The foreign subsidiary must be: incorporated into the EU, OR, pay 15% corporate tax in any country, OR, at least 50% of its revenues come from	0% furniture allowance 0% for non-resident corporate shareholders 0% for resident corporate shareholders 0% for individuals