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

An OECD report on taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
The case sits within a context of Brazil signalling that it is replacing informal discretion and ambiguity with structures that reward analytical rigour, one expert tells ITR
Jeff Soar lifts the lid on WTS UK’s ambitious recruitment plans, the firm's positioning against the big four, and why tax is the perfect profession for AI
Gift this article