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The Netherlands as a holding and
financing jurisdiction
Ton Lekkerkerker
What makes the Netherlands attractive?
- Stable monarchy, King Willem-Alexander
- 17 million inhabitants
- Capital Amsterd...
Other highlights
- Important financial center
- More than 80 banks
- 13 Dutch multinationals in
Fortune Global 500
- Shell...
Participation exemption
• Participation exemption applies to shareholdings
of at least 5% which are not being held as
inve...
Dutch HoldCo
HoldCo
KazakhCoOpCo
≥ 5% Dividends and
capital gainsExemption
Other tax issues
• No withholding tax on interest and royalty
payments abroad
• No stamp duties
• 5% withholding tax on di...
Tax benefits
• Flexible approach for losses
• Innovation box
• Huge tax treaty network, reducing
withholding taxes
• Speci...
Legal aspects
• Branch versus legal entity
• B.V. has no minimum capital
• N.V. EUR 45.000 minimum capital
• Notarial deed...
Migration of existing Cypriot structures
to the Netherlands
• Corporate seat transferred to the
Netherlands
• If effective...
Questions?
• Ton Lekkerkerker
• Lekkerkerker@dirkzwager.nl
• Tel +31 26 355 55 47
• Mobile +31653312666
• www.dirkzwager.n...
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Ton K Lekkerkerker. The Netherlands as a Holding and Financing Jurisdiction 07.06.2013

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Transcript of "Ton K Lekkerkerker. The Netherlands as a Holding and Financing Jurisdiction 07.06.2013"

  1. 1. The Netherlands as a holding and financing jurisdiction Ton Lekkerkerker
  2. 2. What makes the Netherlands attractive? - Stable monarchy, King Willem-Alexander - 17 million inhabitants - Capital Amsterdam - Rotterdam largest seaport in Europe - International infrastructure - 4 direct flights a day Moscow-Amsterdam - Well-educated work force
  3. 3. Other highlights - Important financial center - More than 80 banks - 13 Dutch multinationals in Fortune Global 500 - Shell, Unilever, Heineken - More than 5.000 foreign based companies - Huge tax treaty network - Attractive tax climate
  4. 4. Participation exemption • Participation exemption applies to shareholdings of at least 5% which are not being held as investment participation (intention test). - All benefits exempt for 100% - dividends, forex and capital gains - Losses not tax deductible (exception: liquidation losses) - Expenses tax deductible (exception: acquisition / disposal costs) • Specific rules if the participation is held as an investment participation, • No minimum holding period
  5. 5. Dutch HoldCo HoldCo KazakhCoOpCo ≥ 5% Dividends and capital gainsExemption
  6. 6. Other tax issues • No withholding tax on interest and royalty payments abroad • No stamp duties • 5% withholding tax on dividend to Russian corporate shareholders • Corporate income tax 20% to EUR 250.000 and 25% for excess
  7. 7. Tax benefits • Flexible approach for losses • Innovation box • Huge tax treaty network, reducing withholding taxes • Special tax regime for expatriates • Tax ruling practice
  8. 8. Legal aspects • Branch versus legal entity • B.V. has no minimum capital • N.V. EUR 45.000 minimum capital • Notarial deed for incorporation • Ultimate beneficial owner • Incorporation can be finalized in two weeks
  9. 9. Migration of existing Cypriot structures to the Netherlands • Corporate seat transferred to the Netherlands • If effective business, legal form can be changed from Ltd into B.V. • Cross border legal merger between Ltd and B.V. • Share merger, followed by liquidation • Tax advice should be sought
  10. 10. Questions? • Ton Lekkerkerker • Lekkerkerker@dirkzwager.nl • Tel +31 26 355 55 47 • Mobile +31653312666 • www.dirkzwager.nl • www.legalknowledgeportal.com • www.telfa.org The content of the presentation cannot be applied as legal counselling as this will always be subject to actual and specific knowledge of the client’s situation.
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