Netherlands: Types of Company
For a country to be an attractive location in which to set up a holding company four criteria must be satisfied:
Incoming Dividends: Incoming dividends remitted by the subsidiary to the holding company must either be exempted from or subject to low withholding tax rates in the subsidiary's jurisdiction.
Dividend Income Received: Dividend income received by the holding company from the subsidiary must either be exempted from or subject to low corporate income tax rates in the holding company's jurisdiction.
Capital Gains Tax on Sale of Shares: Profits realized by the holding company on the sale of shares in the subsidiary must either be exempt from or subject to a low rate of capital gains tax in the holding company's jurisdiction.
Outgoing Dividends: Outgoing dividends paid by the holding company to the ultimate parent corporation must either be exempt from or subject to low withholding tax rates in the holding company's jurisdiction. By these criteria Holland is a fiscally attractive jurisdiction in which to locate a holding company. Indeed the holding companies and "participation exemption rules" are one of the Netherlands most attractive features as a tax-planning center.