European holding companies in a changing tax environment

Article Abstract:

The EC's Parent/Subsidiary Directive regulates the tax relationship between parent companies and subsidiaries located in different EC countries. The main goal of the law is to prevent economic and juridical double taxation of the income distributions made by these companies. The member countries are able to amend the directive when they implement it, so not all countries will regulate things similarly. Jan 1, 1992 was the official deadline for acceptance by all countries, though some have not followed through.Tax planning considerations and a guide the level of implementation of the directive are included.

Taxation, International business enterprises, Multinational corporations

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Holding companies in Austria

Article Abstract:

Austrian tax law does not differentiate between holding companies and other types of corporations. The Tax Reform of 1988 liberalized Austrian treatment of foreign holding corporations including exempting dividends and capital gains paid through international participation privilege, lack of regulated debt to equity ratios and a 42 nation tax treaty network. Most transactions involving subsidiary companies are exempt from taxes or receive favorable treatment.

Austria, Income tax

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The holding regime in the Netherlands

Article Abstract:

The Netherlands did not approve the EC Parent/Subsidiary Directive by the Jan 1, 1992 deadline, but has been operating as though the directive were law. Moreover, the Corporate Income Tax Act (CITA) eliminates the possibility of double taxation for qualifying companies. The conditions under which a company may be exempt from participation under the CITA and Dutch interpretation of the EC directive are presented.

Netherlands

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