International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

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 & bottom lb ros

More from across our site

Taxpayers should look beyond the headline criteria of the simplification regime to ensure that their arrangements meet the arm’s-length standard, say Alejandro Ces and Mark Seddon of the EY New Zealand transfer pricing team.
In a recent webinar hosted by law firms Greenberg Traurig and Clayton Utz, officials at the IRS and ATO outlined their visions for 2023.
The Asia-Pacific awards research cycle has now begun – don’t miss on this opportunity be recognised in 2023
An intense period of lobbying and persuasion is under way as the UN secretary-general’s report on the future of international tax cooperation begins to take shape. Ralph Cunningham reports.
Fresh details of the European Commission’s state aid case against Amazon emerge, while a pension fund is suing Amgen over its tax dispute with the Internal Revenue Service.
The OECD’s rules may be impossible for businesses to manage, according to tax experts from companies including Shell.
The UK government is now committed to replacing the ‘super-deduction’ with a 100% capital allowances regime to offset the impact of the corporate tax rise to 25%.
Corporate tax is set to rise in the UK for the first time in decades, but the headline rate remains historically low despite what many observers think.
President Joe Biden’s nominee is set to be confirmed as IRS commissioner for a five-year term.
British companies are waiting to hear the details of what will replace the 130% ‘super-deduction’ next week, while Spain considers stopping a major infrastructure company moving to the Netherlands.