Why Use a Holding Company Structure?
An international holding company can provide significant benefits:
- Asset Protection: Separate operating risks from valuable assets
- Tax Optimization: Route income through efficient jurisdictions
- IP Management: Centralize intellectual property ownership
- Investment Vehicle: Hold shares in subsidiaries across multiple countries
Popular Holding Company Jurisdictions
Netherlands: Participation exemption on dividends and capital gains, extensive tax treaty network (90+ treaties)
Singapore: No capital gains tax, participation exemption available, access to ASEAN
United Kingdom: No withholding tax on dividends paid to non-residents, substantial shareholding exemption
Ireland: Low effective tax rate (12.5%), EU member, strong IP regime
UAE (DIFC/ADGM): 0% corporate tax on qualifying activities, free zone benefits
Common Structures
IP Holding Structure: Company in favorable IP jurisdiction owns and licenses intellectual property to operating entities
Regional Holding: One entity per region holds shares in local subsidiaries
Trading Company Model: Central trading entity handles cross-border transactions
Compliance Requirements
Any international structure must:
- Have genuine economic substance in each jurisdiction
- Comply with transfer pricing rules (arm's length principle)
- Meet beneficial ownership reporting requirements
- Follow CRS/FATCA automatic exchange of information rules
Getting It Right
International structuring is complex and requires professional guidance. Atlas works with qualified tax advisors in each jurisdiction to ensure your structure is both efficient and compliant.
Plan your international structure. Talk to our team.