Editorial

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Editorial

Welcome to the new edition of International Tax Review's Holding Companies guide.

Governments will cling to the right to organise their tax systems in ways that will attract the most foreign direct investment.

Creating the tax environment to make your country attractive as a holding company location is a key tool for governments around the world. The OECD-led discussions on BEPS are likely to lead a tightening of tax rules around the world. However, governments are unlikely to push through changes that will reduce their ability to encourage multinational companies to locate holding companies on their territory.

Jurisdictions who compete for multinationals to establish holding companies in their territory do so through a range of different measures, such as low tax rates, lenient or non-existent controlled foreign company rules and limited transfer pricing regimes.

Cyprus is clear that the days of brass-plate companies are over and a tax-competitive regime, backed up by support for substance, is the future of investment there.

Ireland is also intent on ensuring investors are aware that they must have substance. Indeed, the consensus is that the outcomes from the BEPS project will be positive for jurisdictions such as Ireland, that follow this approach.

While Malta has many attractive tax attributes, they are not the only reasons why investors like the jurisdiction as their holding company location.

And Switzerland appears confident that the impending third tranche of corporate tax reforms will not affect its ability to attract overseas investment.

Ralph Cunningham

Managing editor

International Tax Review

more across site & shared bottom lb ros

More from across our site

Australia’s Tax Practitioners Board is set to kick off 2026 with a new secretary to head the administrative side of its regulatory activities.
Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation
The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes
Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs
The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two
Awards
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued
Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year
Gift this article