Holding-company structuring

The recurring problem

A founder-owned group started life as one operating company in one country. Five years later it has subsidiaries in three more jurisdictions, the founder lives in a fourth, and the next exit will hit a holding structure that nobody designed: it accreted.

We work with mid-cap groups to design (or rebuild) the holding layer so that the next event — refinancing, partial sale, intergenerational transfer, IPO — does not produce a tax friction that nobody priced when the structure was originally bolted together.

Jurisdiction choice

We work jurisdiction-agnostic. The holding country is a function of substance, treaty network, participation exemption regime, exit cost and ongoing reporting burden — not of who happens to have an office nearby. We commonly see Netherlands, Luxembourg, Switzerland, Ireland, Singapore and the UK on the shortlist; we pick on the merits of the specific matter.

Substance discipline

The hardest part of any holding structure is not setting it up but keeping it live. We work alongside the client's in-house team to maintain the substance documentation that the holding country expects and that other tax authorities ask about: board composition, decision record, local management capability, office and IT footprint. We do not provide directors or addresses; we tell you what good looks like and review what you put in place.

Sample work

• Two-tier EU holding redesign for a group with operating subsidiaries in Germany, the Netherlands and the UK, ahead of a partial sale.
• Migration of a Caribbean holding company to Switzerland following the 2024 substance-rules tightening, with a parallel transfer-pricing re-baseline of the inter-company IP licence.
• New Singapore holding company for a Hong Kong industrial group with Indonesian and Vietnamese subsidiaries.