Following the recent financial events in Cyprus, investors maybe considering to change their Cyprus holding and/or finance company to a company located elsewhere in the European Union. The Netherlands offers not only an interesting tax regime but also offers a well established infrastructure. Although the banking sector in the Netherlands is considerable in size – in relation to the economy as a whole – the Dutch economy is established very broadly. Not leaning heavily on one single sector, making it less vulnerable. The Netherlands offers a wide range of interesting tax treaties with in excess of 200 different countries. Furthermore Dutch corporate income tax law offers a 100% participation exemption, there is no withholding tax on interest and royalties, recently the thin capitalisation rules were abolished and transfer pricing rulings can be retrieved from the tax authorities. For e.g. Russian investors the Netherlands could be an interesting alternative for the Cyprus holding and/or finance company because of the tax treaty between Russia and The Netherlands.
In the Netherlands, especially in Amsterdam, many trust offices are established which will amongst others offer management and domiciliation services. These services will be required for the substance of the holding and/or finance company. All trust offices need a permit from the Dutch National Bank and their compliance rules are strict. This will help to keep off the Netherlands from any blacklist.
For any further information you may require to restructure through the Netherlands, please contact us.
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Jan-Hein van Leeuwen
Jan-Hein@okxvanleeuwen.com