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Outbound Acquisitions: European Holding Company Structures

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Outbound Acquisitions: European Holding Company Structures OUTBOUND ACQUISITIONS: EUROPEAN HOLDING COMPANY STRUCTURES Ewout van Asbeck Werner Heyvaert Van Doorne Jones, Day Amsterdam Brussels Nikolaj Bjørnholm Nairy Der Arakelian-Merheje Bech-Bruun Der Arakelian-MerhejeLaw Office Copenhagen Nicosia Willem P. Bongaerts Stephan Neidhardt Loyens & Loeff Walder Wyss & Partners, Ltd. Eindhoven Zurich Guillermo Canalejo Lasarte Luca Rossi Uria Menendez Facchini Rossi Scarioni Madrid Milan Michel Collet Stanley C. Ruchelman CMS-Bureau Francis Lefebvre The Ruchelman Law Firm Paris New York City Oliver Doerfler Robert Schneider KPMG SchneideR’S Rechtsanwalts-KEG Frankfurt Vienna John Hickson Jonathan S. Schwarz A & L Goodbody Temple Tax Chambers Dublin London TABLE OF CONTENTS 1.Introduction ....................................................................................................................... 3 2.Luxembourg ...................................................................................................................... 3 A.General / Participation Exemption ....................................................................... 3 i.Dividends ................................................................................................... 4 ii.Capital Gains ............................................................................................ 4 B.Subject to Tax ....................................................................................................... 4 C.Dividends or Capital Gains after Share Exchange ............................................... 4 D.Luxembourg Permanent Establishment ............................................................... 4 i.Partial participation Exemption ................................................................. 4 E.Withholding Tax in Foreign Subsidiary’s Country ............................................... 4 F.Deduction of Costs ................................................................................................ 5 i.Write-offs ................................................................................................... 5 ii.Financial Costs .......................................................................................... 6 iii.Liquidation Losses ................................................................................... 6 G.Withholding Tax on Outbound Dividends/Capital Gains .................................... 6 i.Dividend Payment ...................................................................................... 6 ii.Interest Payment on (Hybrid) Debt ........................................................... 6 H.Capital Gains in Hands of Shareholders .............................................................. 6 I.Liquidation of a SOPARFI .................................................................................... 6 J.Repurchase of Shares in a SOPARFI .................................................................... 6 K.Other Tax Issues ................................................................................................... 6 i.Debt-Equity Ratio ...................................................................................... 7 ii.Capital Duty .............................................................................................. 7 iii.Annual Net Worth Tax ............................................................................. 7 L.SICAR .................................................................................................................. 7 M.Securitization Vehicle .......................................................................................... 7 3.Denmark ............................................................................................................................ 8 A.In General ............................................................................................................. 8 B.Corporate Income Tax .......................................................................................... 8 C.Withholding Tax in Foreign Subsidiary’s Country .............................................. 9 D.Corporate Taxation of Inbound Dividends ......................................................... 10 E.C.F.C. Taxation ................................................................................................... 10 i.C.F.C. ....................................................................................................... 10 F.Capital Gains Taxation ........................................................................................ 11 2 G.Interest Deductibility Limitations ...................................................................... 11 i.Thin Capitalization ................................................................................... 11 ii.Additional Limitations ............................................................................ 12 iii.Calculation of Net Financial Expense .................................................. 12 iv.Restrictions under the Asset Limitation Rule ...................................... 12 H.Withholding Tax on Outbound Dividends ......................................................... 13 I.Interest Withholding Tax Check-the-Box Countermeasures ............................... 13 J.Transfer Pricing ................................................................................................... 14 K.Group of Companies – Joint Cross Border Taxation ......................................... 14 L.Interim Dividends ............................................................................................... 14 M.Binding Advance Ruling ................................................................................... 14 4.Switzerland ..................................................................................................................... 15 A.In General ........................................................................................................... 15 B.Taxation of Holding Companies ........................................................................ 15 i.Income Tax ............................................................................................... 15 ii.Wealth Tax .............................................................................................. 15 iii.Stamp Duty at Formation ...................................................................... 15 iv.Capital Gains Tax .................................................................................. 15 v.Value-Added Tax (“V.A.T.”) ................................................................... 15 vi.Securities Turnover Tax ......................................................................... 15 vii.Swiss Withholding Tax ......................................................................... 15 viii.Tax Credit for Foreign Withholding Taxes .......................................... 16 ix.Swiss Tax Treaty Network ..................................................................... 16 x.1962 Decree on Misuse of Treaties ......................................................... 16 xi.1998 Circular Letter ............................................................................... 16 xii.Special Rule for Companies with Contacts in the U.S. ........................ 16 xiii.Holding Company Activities .............................................................. 16 C.Additional Tax Related Issues ............................................................................ 16 i.U.S. Check-the Box-Rules ....................................................................... 16 ii.Swiss Ruling Policy ................................................................................ 17 iii.Swiss Debt-Equity Rules ....................................................................... 17 iv.Use of Swiss Holding Companies .......................................................... 17 5.Belgium ........................................................................................................................... 17 A.Corporate Income Tax ........................................................................................ 17 i.General Regime ....................................................................................... 17 ii.Participation Exemption – General ......................................................... 17 3 iii.Dividends Received Deduction ............................................................. 17 a.Minimum Value of participation ................................................. 18 b.Minimum Holding Period ........................................................... 18 c.Subject to Comparable Tax ......................................................... 18 d.Proscribed Business Activities .................................................... 18 e.Offshore Activity ......................................................................... 18 f.Certain Foreign Branch Income .................................................. 18 g.Intermediary Companies ............................................................. 18 h.Other Aspects .............................................................................. 19 i.Ruling Practice ............................................................................. 19 iv.Capital Gain Exemption ......................................................................... 19 a.No Minimum Ownership or Holding Period Requirement ......... 19 b.Options ........................................................................................ 19 c.Unrealized Gains ........................................................................
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