Strategizing Multinational Tax Risks

Loyens & Loeff provides their annual concise and practical holding company update of holding company regimes for 2013.

Click to access Holding_Regimes_2013.pdf

Several topics are covered for each of the following countries

1. Belgium
2. Cyprus
3. Hong Kong
4. Hungary
5. Ireland
6. Luxembourg
7. Malta
8. Netherlands
9. Singapore
10. Spain
11. Switzerland
12. United Kingdom

• Tax on capital contributions
• Corporate income taxes
• Withholding taxes
• Capital gains taxes
• Anti-abuse provisions / CFC rules
• Income tax treaties as of 1/1/2013

This publication is a timely and valuable update, especially with respect to non-European countries and the topics of anti-abuse provisions and CFC rules.

Best Practices should include an annual review of the global legal entity structure, especially with upcoming OECD guidelines, re: general anti-avoidance rules (GAAR), anti-abuse provisions and CFC rules.