Pillar Two: Global Minimum Tax 15%
How the OECD global minimum tax works: €750m threshold, QDMTT/IIR/UTPR, safe harbours, side-by-side for the US, and what it means for private structures.
Pillar Two
Holding Structures: Netherlands, Luxembourg, Cyprus, Singapore, UAE
Holding structures end to end: the investor→holdco→opco path, eight independent tax tests (residence, PE, beneficial ownership, PPT, CFC, TP, substance), NL vs Cyprus flow economics, Pillar Two.
CFC (Controlled Foreign Company): Master Guide to Regimes and Residency Strategies
Comprehensive master guide to CFC (Controlled Foreign Company) rules: core regimes (Russia, US GILTI, UK TIOPA, EU ATAD) and mitigation strategies through tax residency planning.
Holding Company in Switzerland: Rates, Participation Relief, Pillar Two
Swiss holding company: cantonal rates 12–15%, participation relief, TRAF 2020 reform, global minimum tax Pillar Two (QDMTT/IIR), and substance requirements.
Malta Holding: 6/7 Refund System and Effective 5% Rate
How Malta's full imputation system and 6/7 tax refund work, participation exemption for holdings, substance requirements, and the impact of Pillar Two.
Holding in Ireland: 12.5%, participation exemption and Pillar Two
Ireland as a holding jurisdiction: 12.5% on trading profits, participation exemption for foreign dividends from 2025 and for capital gains, 75 tax treaties in force and Pillar Two rules.
CFC in the United Kingdom: TIOPA 2010 Part 9A, TOAA and the FIG Regime
British CFC rules: TIOPA 2010 Part 9A, gateway tests, charge calculation and interaction with Transfer of Assets Abroad and the FIG regime.
UAE Tax Residency: Cabinet Decision 85/2022, Golden Visa and 0% Personal Income Tax
UAE tax residency (Cabinet Decision 85/2022): 183/90-day tests, 0% personal income tax, Golden Visa, TRC, DMTT 15% for large groups from 2025.
EU ATAD I CFC: Articles 7-8 and Member State Implementation
CFC rules under EU ATAD I (Articles 7–8): two approaches to income attribution and implementation across EU Member States for holding structures.
OECD Pillar 2 in Hong Kong: 15% Global Minimum Tax for Large Multinational Groups
From January 1, 2025, Hong Kong applies OECD Pillar 2 at 15% for MNE groups above EUR750M revenue. Impact on private holdings.