Editorial

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Editorial

Welcome to the new edition of International Tax Review's Holding Companies guide.

Governments will cling to the right to organise their tax systems in ways that will attract the most foreign direct investment.

Creating the tax environment to make your country attractive as a holding company location is a key tool for governments around the world. The OECD-led discussions on BEPS are likely to lead a tightening of tax rules around the world. However, governments are unlikely to push through changes that will reduce their ability to encourage multinational companies to locate holding companies on their territory.

Jurisdictions who compete for multinationals to establish holding companies in their territory do so through a range of different measures, such as low tax rates, lenient or non-existent controlled foreign company rules and limited transfer pricing regimes.

Cyprus is clear that the days of brass-plate companies are over and a tax-competitive regime, backed up by support for substance, is the future of investment there.

Ireland is also intent on ensuring investors are aware that they must have substance. Indeed, the consensus is that the outcomes from the BEPS project will be positive for jurisdictions such as Ireland, that follow this approach.

While Malta has many attractive tax attributes, they are not the only reasons why investors like the jurisdiction as their holding company location.

And Switzerland appears confident that the impending third tranche of corporate tax reforms will not affect its ability to attract overseas investment.

Ralph Cunningham

Managing editor

International Tax Review

more across site & shared bottom lb ros

More from across our site

The arrival of a seven-strong team from Baker McKenzie will boost WTS Germany’s transfer pricing capabilities and help it become ‘a European champion’, the firm’s CEO said
Germany has forgotten to think about digital reporting requirements, a WTS partner claimed at ITR’s Indirect Tax Forum 2025
E-invoicing is currently characterised by dynamism, with fragmentation acting as a key catalyst for increasing interoperability, says Aida Cavalera of the International Observatory on eInvoicing
Pillar two and the US tax system ‘could work in harmony’, Scott Levine tells ITR in an exclusive interview to mark his arrival at Baker McKenzie
Peter White, who has a tax debt of A$2 million, has been banned for five years from seeking registration with Australia’s Tax Practitioners Board (TPB)
Wopke Hoekstra’s comments followed US measures aimed against ‘unfair foreign taxes’; in other news, Grant Thornton and Holland & Knight made key tax partner hires
An Administrative Review Tribunal ruling last month in Australia v Alcoa represents a 'concerning trend' for the tax authority, one expert tells ITR
A recent decision underlines that Indian courts are more willing to look beyond just legal compliance and examine whether foreign investment structures have real business substance
Following his Liberal Party’s election victory, one source expects Mark Carney to follow the international consensus on pillar two, as experts assess the new administration
A German economics professor was reportedly ‘irritated’ by how the Finnish ministry of finance used his data
Gift this article