The incorporation of a foreign holding company is an important consideration in many international structures where there is a desire to minimize the tax charged on income and gains.
With the expansion of the European Union and the introduction of a number of directives such as the Parent-Subsidiary Directive, the Merger Directive and the Interest & Royalty Directive combined with the domestic laws of the countries concerned, various European jurisdictions offer interesting and diverse opportunities for the international operations of multi-national enterprises.
One thing is certain - there is not just one optimal holding company jurisdiction to suit all investors or investment profiles. A multitude of tax and non-tax factors are taken into account by investors before they finally decide on a holding company jurisdiction.
It still remains, however, that classic holding company jurisdictions such as the Netherlands, and Luxembourg are now facing new competitors. As the number of EU members grows, some of the newer member states are becoming the preferred choice as a holding jurisdiction. Are new member states such as Malta ousting the traditional choices or may the best results still be achieved by a combination of ‘old’ and ‘new’ jurisdictions?
This conference will provide required knowledge of local business environments and tax laws combined with an overview of how differing local legal / tax systems interact at an international level. A constructive comparison and panel discussion will highlight the distinction between older EU member states and the recent amendments they have made in order to remain/become an attractive jurisdiction and new member states with the advantages they bring in this field.
Sessions will notably include:
- Why is a holding company often used for Multinational Enterprises?
- Various countries' overview by national advisors
- European Court of Justice case-law
- Case-law and reactions by the "other jurisdictions" involved in the structure
Glossary
