Business - Holdings
The use of a European holding allows activating tax planning for the business activity, from at least two companies. Tax saving targets the taxation of dividend incomes; taxation of capital gains, with or without tax on dividend payment, and an option to use a tax treaty. For all these options, the choice of a specific jurisdiction is a complex and one-to-one process. The jurisdictions of application for an European holding: Austria; Belgium; Cyprus; Denmark; Ireland; Luxembourg; Malta; Norway; Netherlands; Spain; Sweden, Switzerland and UK. The FCC, or Foreign Controlled Company is a tax planning concept in the formation and use of a European holding company. From this the concept of a group of companies will arise and be applied to the bank accounts and the management of corporate finance.
Brochure
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The choice of a jurisdiction
Among these jurisdictions, the most interesting are: Austria; Cyprus; Norway; Switzerland and UK. The Austrian holding is very attractive, situated between the east and west of Europe, with more than 70 tax treaties with jurisdictions like Belize; Cyprus; Malta or Liechtenstein for example. Cyprus holding enjoy zero taxation as well as many tax treaties. The "controlled foreign company" or CFC legislation is another factor to consider. Switzerland pure holding has some advantages, as well as an 8% rate of taxation. The latest G20 did not change either bank secrecy or tax heavens, and the corporate tax planning was not considered at all. The corporate structures will be useful to the company doing business on an international level, allowing important tax saving, in a legal way.
Offshore structures
The direct use of an offshore company with the related bank account is another confidential and tax saving option for the businessman undertaking international operations. The last G20 summit provided a white list of politically acceptable jurisdictions. It is wise to follow these recommendations when not using a specific tax agreement or a European holding form, both for the confidentiality and the tax free process. Other forms of offshore structures are available: trust, foundation, holding. A Swiss company, like Gmbh or SA could be useful, especially with the confidential form of the associates in the Swiss SA, and the low taxation for business activities outside Switzerland.