Loyens & Loeff provides their annual concise and practical holding company update of holding company regimes for 2013.
Several topics are covered for each of the following countries
- Hong Kong
- 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.