The UK as a Location for a Holding Company - Income Aspects

Extract

---

The UK as a Location for a Holding Company - Income Aspects

Originally presented to the International Bar Association, Taxes Committee on 10 April at the IBA conference in Dublin for Best Location for Holding Companies.

1. INTRODUCTION

Corporate groups often set up holding companies to provide a command and control function or clear reporting lines for their organisation in a particular region or, more unusually, a product or service line. Although it would be possible to hold a group's operational branches or subsidiaries directly from the ultimate parent, an intermediate holding company makes it easier to control the relevant business segment. Holding companies are also used to finance group activities or expansions and to hold intellectual property.

An ideal holding company jurisdiction would have:

(a) negligible tax cost, but (perhaps impossibly) would not be regarded as a tax haven; and

(b) a comprehensive network of tax treaties.

Whilst tax can ...

See the full content of this document

---