
Corporate Entities
Centralise ownership, isolate risk, and optimise dividend flows across your corporate group with a strategically structured holding company in the right jurisdiction.
Overview
A holding company is a corporate entity whose primary purpose is to own shares — or other interests — in other companies, rather than to conduct operating activities itself. By sitting at the apex of a corporate group, the holding company centralises ownership and strategic decision-making while keeping operational risk contained within individual subsidiaries.
Holding structures are used by businesses of all sizes — from entrepreneurs with two or three operating companies to large multinational groups with hundreds of entities. The benefits are consistent: liability ring-fencing, efficient profit extraction, IP protection, and a clean platform for M&A or exit.
The choice of jurisdiction for the holding company is critical. Factors including tax treaty networks, participation exemption regimes, substance requirements, and BEPS compliance all determine which jurisdiction will deliver the optimal outcome for your specific group.
Typical Group Structure
Holding Company
Strategic Apex
Operating Subsidiary
Trading business
Property SPV
Real estate assets
IP Holding Entity
Intellectual property
Investment Vehicle
Portfolio assets
Why a Holding Company
A holding company sits at the top of a corporate group, owning shares in subsidiaries. This creates a clean, organised structure that separates operational risk from strategic ownership and centralises governance.
Each subsidiary operates as a separate legal entity. Losses or legal claims against one subsidiary cannot flow upward to the holding company or across to other subsidiaries, protecting the group's overall asset base.
Many jurisdictions offer participation exemptions or dividend withholding tax reductions on dividends received by a holding company from its subsidiaries — enabling tax-efficient profit pooling at group level.
Intellectual property assets — patents, trademarks, software licences — can be held in a holding company in a favourable jurisdiction, with royalties charged to operating subsidiaries at arm's length.
A holding company can consolidate multiple investments — listed equities, private equity stakes, real estate — in a single vehicle, simplifying reporting, governance, and eventual succession or exit.
When the time comes to sell a business, selling shares in the holding company rather than individual subsidiaries can simplify the transaction structure and potentially deliver more favourable capital gains treatment.
Where to Incorporate
Substantial shareholding exemption, extensive treaty network
Premier EU holding jurisdiction, participation exemption
Dutch participation exemption, EU treaty access
Zero capital gains, territorial tax system
Regional hub, low corporate tax, major treaty network
Zero tax, minimal compliance, rapid formation
Getting Started
We map your existing corporate structure, identify inefficiencies, and determine the optimal jurisdiction and configuration for the holding company.
We design the holding structure — including ownership percentages, inter-company agreements, and any loan or royalty arrangements — to maximise efficiency.
We assess the tax implications of establishing the holding company, including any controlled foreign corporation rules, transfer pricing, and BEPS considerations.
We incorporate the holding company in the agreed jurisdiction, prepare all constitutional documents, and establish the formal ownership chain.
We manage the transfer of subsidiary shares into the holding company, any inter-company agreements, and ongoing group compliance requirements.
Common Questions
Important: This page is for informational purposes only and does not constitute tax, legal, or financial advice. International holding structures must comply with applicable BEPS, transfer pricing, and substance requirements in each relevant jurisdiction. Always seek independent professional advice.
Speak to an Adviser
Our advisers will analyse your existing corporate structure and design an optimal holding company arrangement to protect assets, reduce tax, and simplify your group.