Anti-abuse measures against the abuse of the Belgian holding regime
Article Abstract:
Belgium's tax laws permit the transfer of securities to a foreign holding company if the transfer can be shown to occur under legitimate conditions and not merely to avoid taxation. Certain companies do not qualify for exemptions of dividend taxes because their country of origin's tax regime is more liberal than Belgium's or comparable countries. Belgium's laws are in accord with those of the EC, with the exception of capital loss deductions.
Publication Name: The International Tax Journal
Subject: Business, international
ISSN: 0097-7314
Year: 1992
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The use of French holding companies
Article Abstract:
France has become an attractive place for the siting of intermediate holding companies since the passage of the EC Parent/Subsidiary Directive. France's tax treaty network of over 80 countries, benevolent treatment of dividend distributions received from foreign subsidiaries and the deductibility of expenses from acquisitions and capital losses. Examples of French tax treatment of the current parent/subsidiary relationship are presented.
Publication Name: The International Tax Journal
Subject: Business, international
ISSN: 0097-7314
Year: 1992
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