Non-tax and tax factors of relevance to selecting a holding jurisdiction
The EU Parent-Subsidiary Directive. This is of importance partly because many of the 27 member countries of the EU offer interesting holding regimes, and further, investing into any of the 27 countries will often be affected by the EU Parent Subsidiary Directive
Relevant domestic and treaty-based anti-avoidance provisions. This focuses on anti-treaty shopping measures in Germany, Switzerland and the United States, as well as anti-abuse provisions under the EU Parent Subsidiary Directive, affecting Austria, France, Germany, Italy and Spain
Description of the key features of the following holding company jurisdictions (this is the main part of the presentation):
6. Luxembourg Soparfi
15. United Kingdom
Case study. Substantial time is dedicated to the case study.
Developing a holding structure.
This case study looks at an onshore publicly listed shareholder on the one hand, and an offshore individual on the other. A holding structure for each is developed during the case study, with the subsidiaries (targets) being the same for both shareholders. Sheltons-SITTI has conducted this case study for 10 years and every month or two the answer changes due to changes in the law. In addition, the ideal holding structure for the onshore publicly listed shareholder is always significantly different to that for the offshore individual.