Holding, financing and management service companies – specific tax aspects

have been under increased pressure from the tax administration, especially in regards to their economic substance. Changes aimed at the activity of such companies have also occurred in the legislative area.

In the training course, we will deal with the most significant issues for the individual company types and show practical approaches to the discussed problems.

Who are the intended participants?

• Executives and managers of supranational corporations
• Tax and accounting professionals dealing with the tax aspects of holding, financing and management service companies

Programme

• Complex tax areas for holding companies, in particular:
  • costs associated with the holding of shares and their tax deductibility
  • the right to VAT deductions on procured services by a holding company.
• Complex tax areas for financing companies, in particular:
  • setting interest rates
  • tax deductibility of interest expenses.
• Complex tax areas for management service companies, in particular:
  • tax deductibility of management service fees on the receiving side
  • management service fees and transfer pricing issues.
• Application of withholding taxes in payments to foreign holding, financing and management service companies, in particular:
  • withholding tax in conventions on the avoidance of double taxation and the Income Tax Act
  • how to proceed when making payments to selected jurisdictions (e.g. the Netherlands, Luxemburg, etc.)
  • beneficial ownership and economic substance issues
  • what to avoid in the application of withholding tax on management service fees.

Benefits

During the course, you will:

• Find out how to deal with tax problems pertaining to holding, financing and management service companies.
• Learn how to assess whether your current holding or financing structure holds any tax risks connected to changes in international and local taxation
• Discover how to identify possible tax risk connected with the provision of intergroup financing and management services.