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Holding companies are often used within multinational groups to centralize the management of the participations held by the group (in a certain geographical area). This intermediate-level course deals with the tax aspects to be taken into account when dealing with holding companies in Europe and offers a detailed but easily accessible and comparable overview of the domestic legislation of countries that are often used as a location to establish holding companies. The course addresses the technicalities of the widely used EC Corporate Direct Tax Directives and the use of holding companies also for financing and IP management activities. The course contains a session on the tax aspects that should be taken into consideration by a US-based group setting up its holding company in Europe. The use of case studies allows participants to apply the principles and knowledge acquired during the course.

Topics covered in this course include:

• Tax Considerations for Holding Companies
• Analysis of the Domestic Legislation in Switzerland, Spain, the Netherlands, Luxembourg, Cyprus, Malta and Gibraltar
• Parent-Subsidiary Directive
• Interest & Royalties Directive
• Merger Directive
• ECJ and domestic case law
• Group Financing and IP Management by Holding Companies
• Key Goals and Objectives for a US Multinational Group