Independent Trust and Corporate Services Provider

Holding Companies

 Ireland and Luxembourg have well established reputations as attractive jurisdictions for the location of holding companies within multinational group structures. Some of the key reasons for the attractiveness of  their tax regimes are their extensive network of double taxation treaties, their positions as onshore EU jurisdictions and the fact that they are members of the OECD.

Our Holding Company Services

  • Company incorporation services
  • Procurement of professionally qualified resident directors
  • Company secretarial services and provision of a registered office
  • Management and administration services
  • Financial reporting and accounting services
  • Treasury and cash management services
  • Bank account reconciliation and administration

The Key Advantages of Locating a Holding Company in Ireland

  • Dividend income received from an EU Member State or from a country with which Ireland has a double taxation treaty that is derived from trading activities is taxed at a corporation tax rate of 12.5%. Corporation tax at a rate of 25% applies to foreign dividends from other companies or from non-trading profits
  • The Irish holding company regime allows for a capital gains tax exemption on the disposal of qualifying shareholdings (minimum 5% shareholding) in companies resident in an EU Member State or in a country where a double taxation treaty with Ireland is in place
  • Where no double tax treaty is in force, Ireland provides for unilateral credit relief for foreign withholding tax and underlying taxes on dividends paid to an Irish resident company which can be utilised to minimise or eliminate Irish tax on dividend income
  • Exemptions can be availed of that allow dividends to be paid by an Irish resident holding company free from Dividend Withholding Tax including where the recipient is resident in an EU Member State/Double Tax Treaty Country or to a company that is not resident in an EU Member State/Double Tax Treaty Country but is controlled by a resident in an EU Member State/Double Tax Treaty Country
  • Interest withholding tax does not apply to interest paid to a resident in an EU Member State or to a country with which Ireland has a double taxation treaty
  • Interest withholding tax does not apply to interest paid on listed bonds or interest paid on commercial paper
  • Double taxation treaties and/or favourable domestic legislation can minimise withholding tax payable on royalties received
  • Ireland has no controlled foreign corporation or thin capitalisation rules
  • Ireland has no capital duty or net wealth taxes
  • Funding costs may be tax deductible

The Key Advantages of Locating a Holding Company in Luxembourg

  • Limited or no withholding tax on dividends paid to a company resident of a country that has a double tax treaty with Luxembourg, under certain conditions
  • No withholding tax on dividends paid between the Luxembourg company and other EU resident companies, under certain conditions
  • No withholding tax on the liquidation process of a holding company
  • Possibility of offsetting financial charges such as capital losses on disposal of shareholdings, acquisition of shareholdings in respect of taxable activities and, under certain conditions, foreign tax credits against profits made from other activities subject of taxation
  • Flexible thin capitalisation rules and possibility of VAT registration
  • Received dividends and capital gains on disposal of shareholding are exempt from taxation under certain conditions