Practice guide: Establishing a holding company

Speed Read: When establishing a holding company, there are a number of tax and commercial factors to consider. The holding company may be taxed on dividends or gains, or may be subject to anti-avoidance rules. Dividends paid by subsidiaries may be subject to withholding tax which is relieved under a double tax agreement, depending on the location of the holding company. The tax position of shareholders must not be forgotten, as their tax position may depend on the location of the holding company, or the withholding tax on dividends.