---
name: family-holding-company-location-compared
description: "Where to put a family holding company: Malta, Cyprus, Ireland, Luxembourg, the Netherlands, Switzerland, Singapore, the UAE and the UK compared on corporate rate, participation exemption for dividends and gains (holding size, period, subject-to-tax tests), withholding on dividends paid out, and Malta's refund system, with a worked hypothetical and the conditions that decide each answer."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/family-holding-company-location-compared"
  jurisdiction: "general"
  tax_year: "2026"
  last_updated: "2026-10-05"
  authored_by: "Michael Cutajar, CPA, ACCA"
  trust_label: "Accountant-authored"
  review_status: "pending_review"
---

# Where to put the family holding company: nine countries compared

Figures are for tax year 2026. This Guide compares Malta, Cyprus, Ireland, Luxembourg, the Netherlands, Switzerland, Singapore, the United Arab Emirates and the United Kingdom as the home of a family holding company. A family holding company here means a company owned by family members that holds shares in one or more operating companies, receives their dividends and sometimes sells a stake. For each country it gives the headline corporate rate, the exemption for dividends and gains from subsidiaries with its conditions, the tax on dividends paid out to the family, and the year each rule applies from. Every figure sits in a table that names its official page. Where an allowed official page does not print a figure, the Guide says "not printed on an allowed page" instead of guessing. Pages were read on 4 October 2026.

This Guide is a first sort. It does not decide residence of the company, CFC exposure of the family member at home, or substance. For those, see `mt-company-residence-and-substance` and `cfc-and-substance-rules-compared`. For Malta in depth, see `mt-holding-company-participation-exemption`. For trusts and foundations as the top of the structure, see `trusts-vs-foundations-by-country`.

## The method, step by step

1. Fix the facts first: where each family member is tax resident, where the operating subsidiaries are resident, the size of each holding, the date each holding was acquired, and whether each subsidiary trades or mainly holds investments or property. Every exemption below turns on these. Use the questions in "Ask the client first".
2. For each candidate country, test the dividend exemption on its own conditions (holding size, holding period, subject-to-tax or anti-abuse test). The country sections below give each test with its law and link, for example Malta's article 12(1)(u) in the [Income Tax Act, Cap. 123](https://legislation.mt/eli/cap/123/eng/pdf).
3. Test the gains exemption separately. In most of these countries the gains test differs from the dividend test (the UK requires a trading subsidiary, Singapore requires a bigger stake held longer, Luxembourg has a higher acquisition-cost alternative). See the UK [CG53072](https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg53072) and Singapore's [section 13W e-Tax Guide](https://www.iras.gov.sg/docs/default-source/e-tax/etaxguide_certainty-of-non-taxation-of-companies-gain-on-disposal-of-equity-investments.pdf?sfvrsn=ceb9a99_18).
4. Work out what happens when money leaves the holding company for the family: the outbound dividend withholding or shareholder-level charge, for individuals and for companies. Malta works through refunds to the shareholder under article 48 of the [Income Tax Management Act, Cap. 372](https://legislation.mt/eli/cap/372/eng/pdf) instead of a withholding tax.
5. Check the family member's home country. A low-taxed holding company may be taxed in the shareholder's own country under its CFC rules, whatever the holding country charges. See `cfc-and-substance-rules-compared`.
6. Flag Pillar Two only if the whole group has consolidated revenue above the threshold in two of the four periods before (see the UK table below) ([MTT11010](https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt11010)). Family groups rarely do.
7. Run the worked hypothetical in "Worked hypothetical" with the client's own numbers, and record which condition each answer depends on.

## Comparison at a glance

Each value in this table is repeated from the sourced country table further down. Read the country section before relying on a row: every exemption has conditions, and failing one usually means the full rate applies.

| Country | Headline corporate rate 2026 | Dividend exemption: holding and period | Gains exemption: holding and period | Outbound dividend tax |
| --- | --- | --- | --- | --- |
| Malta | thirty-five cents on every euro (article 56(6)); elective fifteen cents, final, no refund to the shareholder (L.N. 188 of 2025) | Participating holding (at least five percent of equity, or EUR 1,164,000 held 183 days, among other routes) plus anti-abuse test | Same participating holding test; restricted for Malta-resident investees (art. 12(1)(u) proviso) | Refunds to the shareholder (six-sevenths, five-sevenths, two-thirds or all) on taxed-account dividends; fifteen per cent deducted on untaxed-account dividends to a "recipient" (article 61: mainly Malta-resident persons other than companies, and non-residents controlled by Malta ordinarily resident and domiciled individuals) |
| Cyprus | 15% | All dividends exempt from corporate tax, with one exclusion (dividend deductible for the payer) | All gains on "titles" (shares and similar) exempt | 5% SDC for resident and domiciled individuals on 2026+ profits; 5% or 17% to some non-resident companies |
| Ireland | 12.5% trading; 25% non-trading | At least five per cent for 12 months, foreign subsidiary (from 1 January 2025) | At least 5 per cent for 12 months, trading test | 25% DWT, with exemptions for qualifying non-residents |
| Luxembourg | 16% (top band); 23.87% combined in Luxembourg City | 10% or EUR 1,200,000, held 12 months | 10% or EUR 6,000,000, held 12 months | 15% withholding |
| Netherlands | 19.0% up to EUR 200,000; 25.8% above | At least 5% (participation exemption) | Same participation exemption | 15% dividend tax |
| Switzerland | 8.5 Prozent federal only, plus cantonal tax | Participation reduction (not an exemption), 10 Prozent or one million francs | 10 Prozent held at least one year | 35% withholding tax |
| Singapore | 17% | Singapore dividends one-tier and not taxable; foreign dividends exempt if conditions met (headline rate at least 15%) | At least 20% held 24 months (section 13W) | No tax on one-tier dividends in the shareholder's hands |
| UAE | 9% above AED 375,000 | 5% or AED 4 million, 12 months, subject to tax at 9% or more | Same participation exemption | 0% withholding tax |
| United Kingdom | 25% main rate; 19% small profits rate (limits shared with associated companies; see the UK section) | Distribution exemption (exempt classes, Part 9A of the Corporation Tax Act 2009) | Substantial shareholdings exemption, at least 10% for 12 months, trading investee | Not printed on an allowed page |

Pillar Two: a one-line flag only. It applies to groups with consolidated revenue at the threshold in the UK table (EUR 750 million). Families rarely reach it.

## Malta

Malta taxes a company at a flat rate on chargeable income and then refunds part or all of that tax to the shareholder when the profits are paid out as a dividend. A holding company can also take a participation exemption instead.

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://legislation.mt/eli/cap/123/eng/pdf |
| Company rate, article 56(6) | thirty-five cents on every euro | "The tax shall be charged at the rate of thirty-five cents (0.35) on every euro of the chargeable income of every - ... (a) company" |
| Participating holding, route (a) | at least five percent of the equity shares | "a company holds directly at least five percent of the equity shares of a company" |
| Participating holding, route (e) | EUR 1,164,000 | "a minimum of one million, one hundred and sixty-four thousand euro (€1,164,000)" held "for an uninterrupted period of not less than 183 days" |
| Dividend anti-abuse, limb (i)(2) | 15% | "it is subject to any foreign tax of at least fifteen per cent (15%)" |
| Dividend anti-abuse, limb (i)(3) | 50% | "it does not have more than fifty per cent (50%) of its income derived from passive interest or royalties" |
| Dividend anti-abuse, limb (ii)(2) | 5% | "subject to any foreign tax at a rate which is not less than five per cent (5%)" |
| Tax deducted from an untaxed dividend paid to a recipient, article 62(1) | fifteen per cent | "deduct therefrom tax at a rate of fifteen per cent." |

Rules, from article 12(1)(u) of the [Income Tax Act](https://legislation.mt/eli/cap/123/eng/pdf):

- WHO: a company registered in Malta that holds a "participating holding". The definition in article 2(1) has several routes, any one of which is enough (OR): at least five percent of the equity shares with at least five percent of any two of votes, distributable profits and assets on a winding up; an option to buy the rest of the shares; a right of first refusal; the right to sit on or appoint a director to the board; an investment of at least the amount in the table held for an uninterrupted period of not less than 183 days; or a holding for the furtherance of its own business that is not trading stock.
- WHAT: income or gains from the participating holding, and gains on its transfer, are exempt where the company has not shown them as chargeable income in its return. The company may instead declare them; the shareholder may then claim a refund (below).
- DIVIDEND CONDITIONS: for a dividend from a participating holding acquired on or after 1 January 2007 (and, from 1 January 2011, also one acquired before), the exemption applies only if the subsidiary meets ANY ONE of: resident or incorporated in the EU; subject to foreign tax of at least the 15% in the table; not more than 50% of its income from passive interest or royalties. If it meets none of these, BOTH of these must hold: the holding is not a portfolio investment, AND the subsidiary or its passive interest or royalties were subject to foreign tax of at least 5%.
- EXCLUSION: the exemption does not apply to income from a participating holding in a body resident in a jurisdiction on the EU list of non-cooperative jurisdictions for at least three months in the year before the year of assessment, unless the company proves the body has sufficient significant people functions there.
- GAINS: the dividend conditions above apply to dividends only. A separate proviso covers a participating holding "in a company or in a partnership, EEIG, other body of persons or collective investment scheme ... that is resident in Malta", and holdings that hold such interests directly or indirectly. Gains on those "shall only qualify for the exemption if such gains or profits would have been exempt in terms of sub-paragraph (ii) of paragraph (c) had the transfer of the holding been made by the beneficial owner". Article 12(1)(c)(ii) exempts gains of "any person not resident in Malta". Where there are several beneficial owners, the exemption applies only to the exempt owners' share.

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://legislation.mt/eli/cap/372/eng/pdf |
| Standard refund, article 48(4A)(a) | six-sevenths | "may claim a refund of six-sevenths of the Advance Company Income Tax pertaining to those profits" |
| Passive interest or royalties, or a participating holding dividend that fails the anti-abuse test | five-sevenths | "the rate of refund shall be of five-sevenths of the said Advance Company Income Tax" |
| Profits from a participating holding distributed out of the foreign income account, article 48(4)(b) | all of the Malta tax | "a claim may be made for a refund of all of the Malta tax paid in respect of those profits" |
| Foreign income account profits, article 48(4)(a) (the route where the company claimed double taxation relief, since article 48(4A) is then barred) | two-thirds | "may claim a refund of two-thirds of the Malta tax paid by the company" |

- WHO claims: the shareholder who receives the dividend, and only once registered for the purpose ("provided that such person is for such purpose registered in such manner as may be prescribed").
- NO REFUND under article 48(4A) on foreign income account profits where the company claimed double taxation relief; a two-thirds refund under article 48(4)(a) may then be claimed.
- CAP: the refund never exceeds the tax the company actually paid on the profits distributed.
- NOT SETTLED for Malta-resident individuals: article 12(1)(c)(iii) of the [Income Tax Act](https://legislation.mt/eli/cap/123/eng/pdf) exempts some taxed-account dividends paid to individuals and ties that exemption to the refund bar in the last proviso to article 48(1) of Cap. 372. How that interacts with the article 48(4A) refund was not settled from the text. Refer before telling a Malta-resident individual shareholder to rely on a refund (see `mt-holding-company-participation-exemption`).
- The full refund under article 48(4)(b) for participating holding dividends carries the same anti-abuse conditions as the exemption.

Elective final tax. [L.N. 188 of 2025](https://legislation.mt/eli/ln/2025/188/eng/pdf), the Final Income Tax Without Imputation Regulations, lets an entity elect to be taxed "at the rate of fifteen cents (0.15) on every euro of the chargeable income, in lieu of the rate determined in article 56(6)". It applies to income of the fiscal year preceding year of assessment 2025 and later years. Once elected, the entity cannot switch back before the end of a five-year period, and after switching back the ordinary rules apply for at least five consecutive years of assessment. The election is made by notice in the form and by the date the Commissioner sets. The 15-cent tax "shall be final and shall not be available as a credit or set off against the tax liability of any individual or entity, or as a refund to any person" (reg. 3(4)(b)), so no shareholder refund follows it. It "shall in no case be lower than" the ordinary tax "reduced by the amount of refund claimed or claimable in terms of article 48(4) or (4A)" by all shareholders (reg. 3(4)(a)). The taxed profits go to the final tax account (reg. 3(4)(c)). Chargeable income under the election excludes dividends received from profits that are not "allocated to the final tax account of another company registered in Malta" and income already taxed at a final rate (reg. 3(1) proviso). These regulations are S.L. 123.217.

A Malta company paying a dividend out of its untaxed account to a recipient must, on that payment, "deduct therefrom tax at a rate of fifteen per cent." under article 62(1) of the [Income Tax Act](https://legislation.mt/eli/cap/123/eng/pdf). Article 61 defines a recipient as, among others, a person, other than a company, resident in "Malta in the year in which a dividend is received by him or by any person on his behalf", and "a non-resident person (including a non-resident company) who is owned and controlled by, directly or indirectly, or who acts on behalf of, an individual who is ordinarily resident and domiciled in Malta". The foreign income account holds profits only "to the extent that they result from taxable income"; which account exempt participation income is allocated to is not settled in one sentence of the Act, so refer that question to a Malta accountant before advising. Dividends from taxed accounts carry the refunds above.

## Cyprus

Cyprus raised its corporate rate for 2026 and changed Special Defence Contribution (SDC) on dividends in the same reform. The 15% corporate tax rate below comes from the Tax Department's income tax reform presentation, not from the consolidated law text.

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.gov.cy/media/sites/167/2026/03/2026-%CE%A6%CE%BF%CF%81%CE%9C%CE%B5%CF%84%CE%B1%CF%81%CF%81%CF%8D%CE%B8%CE%BC%CE%B9%CF%83%CE%B7-%CE%A6%CF%8C%CF%81%CE%BF%CF%82-%CE%95%CE%B9%CF%83%CE%BF%CE%B4%CE%AE%CE%BC%CE%B1%CF%84%CE%BF%CF%82.pdf |
| Corporate income tax rate from 1 January 2026 | 15% | "Από την 1/1/2026, οι εταιρείες υπόκεινται σε εταιρικό φόρο με συντελεστή ύψους 15%" |

The Tax Department's [corporate tax page](https://www.gov.cy/mof-tax/documents/epivoli-foroy/) lists dividends ("Μερίσματα Όλα") and gains from the disposal of titles ("Κέρδη που προκύπτουν από τη διάθεση Τίτλων Όλα") as fully exempt from corporate tax. Conditions printed there:

- Dividends: the exemption does not apply where a dividend paid by one company to a Cyprus tax-resident company is deducted from the taxable income of the company paying it. There is no holding percentage or holding period on that page.
- Titles: "shares, debentures, bonds, founders' and other titles of companies or other legal persons", Cypriot or foreign, and rights over them, including options, futures, swaps and units in collective investment schemes.

The SDC figures below come from the Tax Department's presentation of "Ο περί Έκτακτης Εισφοράς για την Άμυνα της Δημοκρατίας (Τροποποιητικός) (Αρ. 4) Νόμος του 2025", in force from 1/1/2026, not from the consolidated law text.

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.gov.cy/media/sites/167/2026/03/EEA-%CE%A6%CE%9A%CE%9A-%CE%9C%CE%95%CE%A4%CE%91%CE%A1%CE%A1%CE%A5%CE%98%CE%9C%CE%99%CE%A3%CE%97-06032026.pdf |
| SDC on dividends received by individuals | 5% | "Άτομα σε ποσοστό 5% (μείωση από το 17%)" |
| SDC on dividends paid out of profits of tax years up to 2025, received up to 31/12/2031 | 17% | "Καταβάλλεται ΕΕΑ σε ποσοστό 17% επί των μερισμάτων που λαμβάνονται από εταιρεία κάτοικο της Δημοκρατίας μέχρι και την 31/12/2031" |
| SDC on foreign dividends received by a Cyprus company, passive and low-taxed payer | 5% | "σε ποσοστό 5% επί των μερισμάτων που λαμβάνει από εταιρεία που δεν είναι κάτοικος στη Δημοκρατία" |
| Passive-activity limb of that test | 50% | "επιδίδεται άμεσα ή έμμεσα περισσότερο από 50% σε δραστηριότητες οι οποίες απολήγουν σε εισόδημα από επένδυση" |
| SDC on dividends paid by a Cyprus company to a non-resident company in a low-tax jurisdiction | 5% | "σε ποσοστό 5%, εάν είναι κάτοικος σε δικαιοδοσία με χαμηλό φορολογικό συντελεστή" |
| Same, non-cooperative jurisdiction | 17% | "σε ποσοστό 17%, εάν είναι κάτοικος σε μη συνεργάσιμη δικαιοδοσία" |
| Shares that count as Cyprus property for capital gains tax | 20% | "εάν τουλάχιστον το 20% (αντί του 50%) της αγοραίας αξίας τους προέρχεται από την ακίνητη ιδιοκτησία στη Δημοκρατία" |
| Deemed distribution: share of 2024 and 2025 profits | 70% | "εβδομήντα τοις εκατό (70%) των κερδών της που κτήθηκαν ή προέκυψαν στα φορολογικά έτη 2024 και 2025" |
| SDC on the deemed distribution | 17% | "Η λογιζόμενη διανομή φορολογείται στο 17%." |

- Individuals: SDC on dividends is charged on a Cyprus-resident individual who is also domiciled; the presentation states "Διατηρείται το καθεστώς non-dom" (the non-dom regime is kept). Dividends out of profits of tax years up to and including 2025 stay at 17% if received up to 31/12/2031; dividends out of 2026 and later profits are at 5%. Read both rows above together.
- Foreign dividends into a Cyprus holding company: SDC at 5% applies only where the paying company BOTH engages directly or indirectly more than 50% in activities producing investment income AND bears foreign tax lower than 50% of the Cyprus tax burden. Otherwise no SDC is printed for this case.
- Dividends paid to a non-resident company: the new article 3(1)(d) charges SDC on a non-resident company receiving dividends from a Cyprus company, at 5% if it is resident (or incorporated and not resident elsewhere) in a low-tax jurisdiction, and at 17% if in a non-cooperative jurisdiction. If a jurisdiction is on both lists, 17% applies.
- The Tax Department's [withholding page for payments to non-residents](https://www.gov.cy/mof-tax/documents/parakratiseis-foroy-se-pliromes-pros-mi-forologikoys-katoikoys-kyproy/) lists royalties, film rentals and professional and artists' fees. It does not list dividends.
- Property-rich shares: shares of a company that directly holds Cyprus immovable property, or indirectly where at least the 20% in the table of market value comes from it, are "property" for capital gains tax, which is outside the corporate tax exemption for titles. A treaty that taxes only above a 50% value test can override this.
- A Cyprus-resident company is still deemed to distribute part of its 2024 and 2025 profits (rows above); this applies only to profits attributable to a person resident in Cyprus on the deemed distribution date ("εφαρμόζονται μόνο στα κέρδη που αναλογούν άμεσα ή έμμεσα σε άτομο το οποίο ... ήταν κάτοικος της Δημοκρατίας"). It is abolished for profits of 2026 onward ("Κατάργηση της λογιζόμενης διανομής των κερδών των ετών από το 2026 και εντεύθεν").

## Ireland

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.revenue.ie/en/companies-and-charities/corporation-tax-for-companies/corporation-tax/basis-of-charge.aspx |
| Trading income | 12.5% | "There are two rates of Corporation Tax (CT): 12.5% for trading income" |
| Non-trading income (rental, investment) and excepted trades | 25% | "25% for: income from an excepted trade ... non trading income, for example rental and investment income" |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.revenue.ie/en/personal-tax-credits-reliefs-and-exemptions/tax-relief-charts/index.aspx |
| Dividend withholding tax (DWT), 2026 | 25% | "Tax Rate: Schedule F (WH = Withholding Tax) 25% WH" |

- Foreign dividends, [participation exemption](https://www.revenue.ie/en/companies-and-charities/reliefs-and-exemptions/exemption-foreign-distributions/index.aspx) (section 831B): for a distribution made on or after 1 January 2025, a parent company that holds at least five per cent of the ordinary share capital for a continuous period of at least 12 months, including the date of the distribution, may claim exemption. The subsidiary must be resident in a relevant territory (EU or EEA country or treaty country, not on the EU list of non-cooperative jurisdictions) and not generally exempt from foreign tax. For distributions from 1 January 2026, that status must have held throughout the preceding three years (five years for 2025). From 2026, a "relevant territory" includes a non-treaty country that generally applies a withholding tax on cross-border distributions. Distributions received as trading income and distributions deductible abroad are excluded. The claim covers ALL relevant distributions from ALL relevant subsidiaries for the accounting period: it cannot be made per dividend or per subsidiary, and the alternative is a double tax credit.
- Gains, [section 626B](https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-20/20-01-14.pdf): a gain on disposal of shares is not a chargeable gain where the investor company has held a "real" holding of at least 5 per cent for a continuous period of 12 months (the disposal must be while it is a parent or within 2 years after), the investee is resident in an EU state or treaty territory, AND at the time of disposal the investee or the group is wholly or mainly (more than half) trading. The exemption does not apply to shares deriving the greater part of their value from land or minerals in the State.
- Outbound: Irish companies withhold DWT at the rate in the table. A [qualifying non-resident](https://www.revenue.ie/en/companies-and-charities/dividend-withholding-tax/exemptions-for-non-residents.aspx) can claim exemption by declaration (Form V2B for a company, V2A for an individual). For an individual this means not resident or ordinarily resident in Ireland and resident in an EU or EEA state or treaty country. For a company it includes one resident in such a territory that is not directly or indirectly controlled by an Irish resident. The exemption is not automatic and lasts until 31 December of the fifth year after issue.
- A family-owned Irish company will often be a [close company](https://www.revenue.ie/en/companies-and-charities/corporation-tax-for-companies/corporation-tax/close-companies.aspx) (controlled by five or fewer participators, or by its directors). Part 13 of the Tax and Duty Manuals then applies; its rates are not printed on the pages read for this Guide.

## Luxembourg

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://impotsdirects.public.lu/fr/az/t/tarif-applicable-collectivites/tarif-collect.html |
| Corporate income tax (IRC), top band, from tax year 2025 | 16% | "16% lorsque le revenu imposable dépasse 200.000 euros" |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://impotsdirects.public.lu/fr/az/c/charg_fisc.html |
| Combined IRC, employment fund surcharge and municipal business tax, Luxembourg City, from 2025 | 23.87% | row "Charge fiscale d'une collectivité au taux d'imposition nominal (A+B+C)", last column "à partir de 2025", printed as 23,87% |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://impotsdirects.public.lu/fr/az/r/regi_soc.html |
| Dividend exemption: minimum holding | 10% | "le taux de participation ne descend pas au-dessous du seuil de 10 % ou le prix d'acquisition au-dessous de 1.200.000 €" |
| Dividend exemption: alternative acquisition price | EUR 1,200,000 | same sentence |
| Gains exemption: alternative acquisition price | EUR 6,000,000 | "ne descend pas au-dessous du seuil de 10 % ou le prix d'acquisition au-dessous de 6.000.000 €" |

This page was last updated on 9 January 2017.

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://impotsdirects.public.lu/dam-assets/fr/legislation/LIR/texte-coordonn-en-vigueur-au-1er-janvier-2026-ver-08052026.pdf |
| Withholding tax rate on dividends, article 148 | 15% | "Le taux de la retenue est fixé à 15%." |

- The 16% in the first table is the top band of the corporate income tax only. The combined figure is the authority's own example for a company seated in the commune of Luxembourg; other communes differ. The coordinated law text in force on 1 January 2026 carries the same 16% in article 174.
- Dividend exemption (article 166 LIR): a fully taxable resident capital company, or a qualifying permanent establishment, holding directly a participation in a fully taxable resident company, a non-resident company fully subject to a tax corresponding to IRC, or an EU company, is exempt on the dividend where, on the date the income is made available, it holds or undertakes to hold the participation for an uninterrupted period of at least 12 months AND throughout that period the holding does not fall below 10% OR the acquisition price does not fall below the amount in the table. If the 12 months are not reached, the exemption is withdrawn by a corrective assessment.
- Gains: the same holding period and 10% test, with the higher acquisition-price alternative in the table.
- Outbound: the authority's page states that a company paying an exempt participation dividend is, under certain conditions, exempt from withholding. That page (last updated 9 January 2017) prints an older withholding rate; the law in force on 1 January 2026 prints the rate in the last table. Use the law.

## Netherlands

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/tarieven_vennootschapsbelasting |
| Band limit | EUR 200,000 | "tot en met € 200.000 19,0% boven € 200.000 25,8%" |
| Rate up to and including the band limit | 19.0% | same |
| Rate above the band limit | 25.8% | same; the page heads the table "De tarieven voor de vennootschapsbelasting in 2026, 2025, 2024 en 2023" |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/deelnemingsvrijstelling/deelnemingen |
| Participation: minimum holding | 5% | "U bent voor ten minste 5% van het nominaal gestorte kapitaal aandeelhouder van een vennootschap" |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/dividendbelasting/als_u_dividend_uitkeert/als_u_dividend_uitkeert |
| Dividend tax rate | 15% | "Het tarief van de dividendbelasting is 15%." |

- Participation exemption: where a participation exists (at least 5% of the paid-up nominal capital, among other routes on the page), profits from it are generally exempt. A holding below 5% cannot be a participation, with one exception: a participation of at least 5% held for more than 1 year that falls below 5% keeps the exemption for 3 more years.
- The exemption "is niet van toepassing op een niet-kwalificerende beleggingsdeelneming"; the credit method (deelnemingsverrekening) applies instead. Whether a participation is held as an investment "hangt onder meer af van het oogmerk"; a top holding company with a real management, policy or financing function for the group may not hold it as an investment. A participation whose assets are mostly holdings below 5%, or whose function is mostly group financing, is always a portfolio participation. See [Deelnemingsvrijstelling](https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/deelnemingsvrijstelling/deelnemingsvrijstelling) and [Wanneer is een deelneming een beleggingsdeelneming?](https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/deelnemingsvrijstelling/wanneer_is_een_deelneming_een_beleggingsdeelneming).
- Holding period: none is printed on the page for the basic test.
- Outbound to a Dutch resident individual: the paying company "meestal" withholds the rate in the table on a portfolio dividend.
- Outbound to a company: on a participation dividend (5% or more) to a Dutch company, the company usually applies the withholding exemption. To a company in a [country with which the Netherlands has a tax treaty](https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/dividendbelasting/als_u_dividend_uitkeert/deelnemingsdividend-uitkeren-aan-aandeelhouder-buiten-nederland), the exemption applies where "er geen sprake van misbruik" is (there is no abuse). With no treaty, the dividend is not exempt and the company withholds the rate in the table.
- For Dutch corporate tax in full, see `nl-corporate-tax`.

## Switzerland

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.estv.admin.ch/estv/de/home/verrechnungssteuer.html |
| Withholding tax (Verrechnungssteuer) on investment income | 35% | "Der Steuersatz beträgt 35 % auf Kapitalerträgen und Lottogewinnen" |

The federal rules come from the [Federal Direct Tax Act (DBG), status 1 January 2026](https://www.fedlex.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/1991/1184_1184_1184/20260101/de/pdf-a/fedlex-data-admin-ch-eli-cc-1991-1184_1184_1184-20260101-de-pdf-a.pdf). The Act writes percentages as words, so they are quoted here as printed:

- Rate, article 68: "Die Gewinnsteuer der Kapitalgesellschaften und Genossenschaften beträgt 8,5 Prozent des Reingewinns." This is the federal tax only. Cantonal and communal profit taxes come on top and are not covered by this Guide.
- Participation reduction, article 69: the federal profit tax is REDUCED in the ratio of net participation income to total net profit (it is not an exemption) where the company holds at least "10 Prozent am Grund- oder Stammkapital" OR at least "10 Prozent am Gewinn und an den Reserven" of another company, OR holds participation rights with a market value of at least one million francs.
- Net income, article 70: participation income less related financing costs and a flat contribution of "5 Prozent zur Deckung des Verwaltungsaufwandes" (or actual administrative costs if proved). Write-downs linked to the income reduce the relief.
- Gains, article 70(4): count only to the extent the sale price exceeds cost, AND only if the holding sold was at least 10 Prozent of capital or of profits and reserves AND was held for at least one year. After a part sale takes the holding below 10 Prozent, later sales qualify only if the holding had a market value of at least one million francs at the end of the tax year before the sale.
- Outbound: the withholding tax in the table is charged on dividends. For a Swiss-resident recipient it is a security tax that is credited or refunded; for others, treaty relief applies on claim. The treaty rates are not printed on the page read.

## Singapore

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.iras.gov.sg/taxes/corporate-income-tax/basics-of-corporate-income-tax/corporate-income-tax-rate-rebates-and-tax-exemption-schemes |
| Corporate income tax rate | 17% | "Your company is taxed at a flat rate of 17% of its chargeable income." |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.iras.gov.sg/media/docs/default-source/e-tax/tax-exemption-for-foreign-sourced-income285e5d43d6af4001b3ce35da1e9005b5.pdf |
| Foreign headline tax rate condition | 15% | "“Foreign headline tax rate of at least 15%” condition" |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.iras.gov.sg/docs/default-source/e-tax/etaxguide_certainty-of-non-taxation-of-companies-gain-on-disposal-of-equity-investments.pdf?sfvrsn=ceb9a99_18 |
| Section 13W minimum shareholding | 20% | "the divesting company must still hold at least 20% of the ordinary shares and/or qualifying preference shares" |

- Singapore dividends: under the one-tier system, dividends paid by a Singapore resident company are not taxable in the shareholder's hands ("as the tax paid by a company is final"), except dividends from co-operatives ([IRAS dividends page](https://www.iras.gov.sg/taxes/individual-income-tax/basics-of-individual-income-tax/what-is-taxable-what-is-not/dividends)).
- Foreign dividends received in Singapore by a resident company are exempt only if ALL three conditions hold: the income was subject to tax abroad; the foreign headline corporate rate is at least the 15% in the table when the income is received; AND the Comptroller is satisfied the exemption benefits the company. Foreign income is generally taxable when remitted to and received in Singapore.
- Gains, section 13W: for disposals from 1 January 2026, gains on ordinary shares and/or qualifying preference shares are not taxable if the divesting company held at least the 20% in the table for a continuous period of at least 24 months immediately before the disposal; from 2026 the 20% may be tested on a group basis. The scheme does not apply to non-listed shares in a company that trades immovable property, or whose principal activity is holding immovable property (Singapore or elsewhere, for disposals from 1 June 2022), or a company that "has undertaken property development activities (in Singapore or elsewhere)", unless it uses the property in its own trade and did no development in the past 60 months. A gain outside section 13W is not automatically taxable; it turns on the facts.

## United Arab Emirates

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://tax.gov.ae/DataFolder/Files/Guides/CT/CT%20General%20Guide%20-%20EN%20-%2010%2009%202023.pdf |
| Rate on taxable income up to the threshold | 0% | "0% (zero percent) on the portion of the Taxable Income not exceeding AED 375,000" |
| Threshold | AED 375,000 | same |
| Rate above the threshold | 9% | "9% (nine percent) on" the portion above |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://tax.gov.ae/Datafolder/Files/Guides/CT/CT%20-%20Exempt%20Income%20-%20Dividends%20and%20Participation%20Exemption%20-%2016%2010%202023.pdf |
| Minimum ownership | 5% | "represents a 5% or greater ownership interest in a Participation" |
| Alternative acquisition cost | AED 4 million | "equal to or exceeds a specific threshold (AED 4 million)" |
| Subject-to-tax rate | 9% | "equivalent foreign corporate tax at a rate of 9% or" more |
| Asset test | 50% | "Not more than 50% of the direct and indirect assets of the Participation must consist of ownership interests which would not qualify" |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://tax.gov.ae/Datafolder/Files/Legislation/Corporate%20Tax/CT%20law%20final/Federal%20Decree-Law%20No.%2047%20of%202022%20-%20For%20publishing.pdf |
| Withholding tax, article 45 | 0% | "subject to Withholding Tax at the rate of 0% (zero percent) or any other rate as specified in a decision issued by the Cabinet" |

- Participation exemption (article 23): ALL of these must hold: ownership of at least 5% OR acquisition cost of at least AED 4 million; held, or intended to be held, for an uninterrupted period of at least 12 months; the participation is subject to UAE corporate tax or an equivalent foreign tax at 9% or more (with exceptions in the guide); the interest entitles the holder to at least 5% of profits and liquidation proceeds; AND not more than 50% of the participation's direct and indirect assets are interests that would not qualify if held directly. Dividends from UAE resident companies are exempt without the participation tests ([Corporate Tax Law, article 22](https://tax.gov.ae/Datafolder/Files/Legislation/Corporate%20Tax/CT%20law%20final/Federal%20Decree-Law%20No.%2047%20of%202022%20-%20For%20publishing.pdf)).
- Gains on the disposal of a participating interest are exempt under article 23(5)(b) on the same participation conditions, for gains "derived after expiry of the 12-month holding period" ([Exempt Income: Dividends and Participation Exemption](https://tax.gov.ae/Datafolder/Files/Guides/CT/CT%20-%20Exempt%20Income%20-%20Dividends%20and%20Participation%20Exemption%20-%2016%2010%202023.pdf), section 6.2.1).
- For setting up a UAE company, see `ae-company-formation`.

## United Kingdom

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.gov.uk/government/publications/rates-and-allowances-corporation-tax/rates-and-allowances-corporation-tax |
| Main rate, financial year from 1 April 2026 | 25% | "Main rate (companies with profits over £250,000) 25% 25%" |
| Small profits rate | 19% | "Small profits rate (companies with profits under £50,000) 19%" |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg53072 |
| Substantial shareholding | 10% | "when it holds at least 10% of the ordinary share capital of the investee company" |

| Item | Value | Note (verbatim from the page) |
| --- | --- | --- |
| Source | all figures below | https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt11010 |
| Pillar Two revenue threshold, 365-day period | EUR 750 million | "The revenue threshold is €750 million for an accounting period of 365 days." |

- Dividends: a company that is not small is exempt on a distribution that falls into an exempt class in sections 931E to 931I of the Corporation Tax Act 2009, is not a deemed interest distribution, AND is not deductible for any foreign resident ([INTM653010](https://www.gov.uk/hmrc-internal-manuals/international-manual/intm653010)). The exempt classes and anti-avoidance rules are in INTM653000 to INTM654000 and are not reproduced here.
- A small company has its own exemption ([INTM650000](https://www.gov.uk/hmrc-internal-manuals/international-manual/intm650000) lists "Exemption for small companies"), not covered here. For the rate bands, HMRC's [Marginal Relief page](https://www.gov.uk/guidance/corporation-tax-marginal-relief) says the limits are divided by the number of associated companies plus one, profits include "distributions from unrelated, unassociated companies", and "You cannot claim Marginal Relief if ... you’re a close investment holding company".
- Gains, substantial shareholdings exemption: the investing company must hold at least 10% of ordinary share capital AND be entitled to at least 10% of distributable profits and of assets on a winding up ([CG53072](https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg53072)), for a continuous period of at least 12 months; for disposals from 1 April 2017 that period may end up to five years before the disposal ([CG53078](https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg53078)). The investee must be a qualifying (trading) company throughout the qualifying period ([CG53106](https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg53106)). Since 1 April 2017 the investing company itself need not be trading.
- Pillar Two: the threshold in the table must be exceeded in two of the four periods immediately before the tested period.
- Outbound dividend withholding: not printed on an allowed page, on the pages read for this Guide.

## Worked hypothetical

Hypothetical facts, not a real client. A family holding company receives a dividend of EUR 1,000,000 from an operating subsidiary and sells a stake at a gain of EUR 5,000,000. The subsidiary is a trading company resident in an EU state with a 15% or higher headline rate, the holding is thirty percent and has been held for three years, and no country's anti-abuse rule is triggered. Because the subsidiary is resident in the EU, not in Malta, and holds no Malta-resident interests, the article 12(1)(u) gains proviso above does not apply. All amounts are before any tax in the shareholder's home country.

| Item | Value | Note |
| --- | --- | --- |
| Source | all figures below | https://legislation.mt/eli/cap/123/eng/pdf |
| Hypothetical dividend | EUR 1,000,000 | assumption |
| Hypothetical gain | EUR 5,000,000 | assumption |

Under those facts, each country's exemption above is met for both items, so the holding-level tax is nil in Malta, Cyprus, Ireland (section 831B elected, 626B met), Luxembourg, the Netherlands, Singapore (FSIE and section 13W met), the UAE and the UK. Switzerland reduces the federal tax instead of exempting: the reduction is in proportion to NET participation income (after financing costs and the 5 Prozent administrative charge), so some federal tax remains, and cantonal tax is outside this Guide. The difference between the countries is therefore in the cases where a condition fails, and in what the family pays when cash comes out.

Malta, condition fails. Assume instead the subsidiary is outside the EU and fails both anti-abuse limbs, no double taxation relief is claimed, and the dividend is paid on to a registered shareholder.

| Step | Value | Note |
| --- | --- | --- |
| Source | all figures below | https://legislation.mt/eli/cap/372/eng/pdf |
| Malta tax at thirty-five cents per euro on the dividend | EUR 350,000 | hypothetical, article 56(6) Cap. 123 |
| Refund to shareholder at five-sevenths | EUR 250,000 | hypothetical, article 48(4A)(a)(i) |
| Malta tax left after refund | EUR 100,000 | hypothetical |

Malta refund on trading profit, for contrast. A Malta company with hypothetical trading profit of EUR 100,000 allocated to its Maltese taxed account, distributed to a registered shareholder.

| Step | Value | Note |
| --- | --- | --- |
| Source | all figures below | https://legislation.mt/eli/cap/372/eng/pdf |
| Hypothetical trading profit | EUR 100,000 | assumption |
| Malta tax at thirty-five cents per euro | EUR 35,000 | hypothetical |
| Refund at six-sevenths | EUR 30,000 | hypothetical, article 48(4A)(a) |
| Malta tax left after refund | EUR 5,000 | hypothetical |

Netherlands, condition fails. Assume the holding is below 5% and never met the 1-year rule, so the dividend is taxable, and the company has no other income or deductions.

| Step | Value | Note |
| --- | --- | --- |
| Source | all figures below | https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/tarieven_vennootschapsbelasting |
| First EUR 200,000 at 19.0% | EUR 38,000 | hypothetical |
| Remaining EUR 800,000 at 25.8% | EUR 206,400 | hypothetical |
| Dutch corporate tax on the dividend | EUR 244,400 | hypothetical |

Netherlands, cash out to a Dutch-resident family member. A hypothetical EUR 1,000,000 portfolio dividend paid to a Dutch-resident individual usually carries dividend tax at the rate in the Dutch table, credited against the individual's income tax.

| Step | Value | Note |
| --- | --- | --- |
| Source | all figures below | https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/dividendbelasting/als_u_dividend_uitkeert/als_u_dividend_uitkeert |
| Dividend tax withheld at 15% | EUR 150,000 | hypothetical |

Cyprus, condition fails. Assume the subsidiary is a non-resident company more than 50% in investment-income activities and taxed abroad at less than 50% of the Cyprus burden.

| Step | Value | Note |
| --- | --- | --- |
| Source | all figures below | https://www.gov.cy/media/sites/167/2026/03/EEA-%CE%A6%CE%9A%CE%9A-%CE%9C%CE%95%CE%A4%CE%91%CE%A1%CE%A1%CE%A5%CE%98%CE%9C%CE%99%CE%A3%CE%97-06032026.pdf |
| SDC at 5% on the dividend | EUR 50,000 | hypothetical; corporate tax exemption still applies |

Not computed: Ireland, Luxembourg, Switzerland, Singapore, the UAE and the UK fail cases. Each depends on facts this hypothetical does not fix (trading or non-trading rate in Ireland, commune in Luxembourg, canton in Switzerland, whether a gain is capital in Singapore, the AED threshold in the UAE, the GBP bands and marginal relief in the UK).

## How to choose

- If the family needs cash paid out regularly to individuals, compare the outbound row first: Singapore one-tier dividends and the UAE rate in the table cost nothing at the holding level on the way out; Malta works through refunds and deducts fifteen per cent on untaxed-account dividends paid to Malta-resident individuals; Ireland, Luxembourg, the Netherlands and Switzerland withhold at the rates in their tables unless an exemption applies; Cyprus charges SDC only on resident individuals and on some non-resident companies.
- If the holding is small or recent, the thresholds decide: Singapore section 13W needs at least 20% for 24 months; Luxembourg needs 10% or a large acquisition price for 12 months; the UK needs 10% for 12 months and a trading investee; Ireland, the Netherlands, Malta and the UAE start at 5%; Cyprus prints no minimum on the Tax Department page.
- If the subsidiaries are in low-tax or non-EU countries, the subject-to-tax tests decide: Malta's anti-abuse limbs, Singapore's 15% headline test, the UAE's 9% test, Ireland's relevant-territory test, the Netherlands' portfolio participation test and Cyprus's passive-and-low-tax SDC rule.
- If a subsidiary holds property, check the property carve-outs: Ireland 626B (Irish land), Singapore section 13W (property-trading or property-holding investees), Cyprus capital gains tax on property-rich shares.
- Then check the family member's own country (CFC) and where the company is really managed (residence and substance) before deciding. See `cfc-and-substance-rules-compared` and `mt-company-residence-and-substance`.

## Ask the client first

- Where is each family shareholder tax resident and domiciled, and where will they be in five years?
- Where are the operating subsidiaries resident, what headline and actual tax do they pay, and do they trade or mainly hold investments or property?
- What percentage of each subsidiary will the holding own, at what acquisition cost, and since what date?
- Does the family need regular cash dividends, or will profits stay in the holding for reinvestment or a later sale?
- Where will the board meet and who will run the holding day to day?
- Does the group's consolidated revenue come anywhere near the Pillar Two threshold?

## When to refuse or refer

- Refer to a licensed adviser in the chosen country before relying on any exemption: every one has conditions, anti-avoidance rules and filings this Guide summarises but does not reproduce in full.
- Refer if any subsidiary is in a jurisdiction on the EU list of non-cooperative jurisdictions, or in a no-tax or low-tax country: several tests here fail in that case.
- Refer for Swiss cantonal tax, Luxembourg municipal tax outside Luxembourg City, Irish close company surcharges and UK exempt-class detail, which this Guide does not compute.
- Refer the shareholder's home-country position (CFC, exit tax, treaty residence) to an adviser in that country.
- Refuse to treat the comparison table as a recommendation for a specific family without the facts in "Ask the client first".
- Refer Malta-specific questions (refund mechanics, the elective final tax, residence and substance) to `mt-holding-company-participation-exemption` and `mt-company-residence-and-substance`; Malta also has `mt-capital-gains` for sales of shares.

## Sources

- Malta: [Income Tax Act, Cap. 123](https://legislation.mt/eli/cap/123/eng/pdf); [Income Tax Management Act, Cap. 372](https://legislation.mt/eli/cap/372/eng/pdf); [L.N. 188 of 2025](https://legislation.mt/eli/ln/2025/188/eng/pdf)
- Cyprus: [Income tax reform presentation 2026](https://www.gov.cy/media/sites/167/2026/03/2026-%CE%A6%CE%BF%CF%81%CE%9C%CE%B5%CF%84%CE%B1%CF%81%CF%81%CF%8D%CE%B8%CE%BC%CE%B9%CF%83%CE%B7-%CE%A6%CF%8C%CF%81%CE%BF%CF%82-%CE%95%CE%B9%CF%83%CE%BF%CE%B4%CE%AE%CE%BC%CE%B1%CF%84%CE%BF%CF%82.pdf); [SDC and CGT reform presentation](https://www.gov.cy/media/sites/167/2026/03/EEA-%CE%A6%CE%9A%CE%9A-%CE%9C%CE%95%CE%A4%CE%91%CE%A1%CE%A1%CE%A5%CE%98%CE%9C%CE%99%CE%A3%CE%97-06032026.pdf); [Corporate tax page](https://www.gov.cy/mof-tax/documents/epivoli-foroy/); [Withholding on payments to non-residents](https://www.gov.cy/mof-tax/documents/parakratiseis-foroy-se-pliromes-pros-mi-forologikoys-katoikoys-kyproy/)
- Ireland: [Basis of charge](https://www.revenue.ie/en/companies-and-charities/corporation-tax-for-companies/corporation-tax/basis-of-charge.aspx); [Tax relief charts](https://www.revenue.ie/en/personal-tax-credits-reliefs-and-exemptions/tax-relief-charts/index.aspx); [Participation exemption for foreign distributions](https://www.revenue.ie/en/companies-and-charities/reliefs-and-exemptions/exemption-foreign-distributions/index.aspx); [TDM Part 20-01-14](https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-20/20-01-14.pdf); [DWT exemptions for non-residents](https://www.revenue.ie/en/companies-and-charities/dividend-withholding-tax/exemptions-for-non-residents.aspx); [Close companies](https://www.revenue.ie/en/companies-and-charities/corporation-tax-for-companies/corporation-tax/close-companies.aspx)
- Luxembourg: [IRC rates](https://impotsdirects.public.lu/fr/az/t/tarif-applicable-collectivites/tarif-collect.html); [Overall tax burden](https://impotsdirects.public.lu/fr/az/c/charg_fisc.html); [Parent-subsidiary regime](https://impotsdirects.public.lu/fr/az/r/regi_soc.html); [LIR coordinated text at 1 January 2026](https://impotsdirects.public.lu/dam-assets/fr/legislation/LIR/texte-coordonn-en-vigueur-au-1er-janvier-2026-ver-08052026.pdf)
- Netherlands: [Corporate tax rates](https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/tarieven_vennootschapsbelasting); [Participations](https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/deelnemingsvrijstelling/deelnemingen); [Dividend tax when paying dividends](https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/dividendbelasting/als_u_dividend_uitkeert/als_u_dividend_uitkeert); [Participation dividend to a shareholder abroad](https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/dividendbelasting/als_u_dividend_uitkeert/deelnemingsdividend-uitkeren-aan-aandeelhouder-buiten-nederland)
- Switzerland: [DBG, status 1 January 2026](https://www.fedlex.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/1991/1184_1184_1184/20260101/de/pdf-a/fedlex-data-admin-ch-eli-cc-1991-1184_1184_1184-20260101-de-pdf-a.pdf); [ESTV withholding tax](https://www.estv.admin.ch/estv/de/home/verrechnungssteuer.html)
- Singapore: [Corporate income tax rate](https://www.iras.gov.sg/taxes/corporate-income-tax/basics-of-corporate-income-tax/corporate-income-tax-rate-rebates-and-tax-exemption-schemes); [FSIE e-Tax Guide](https://www.iras.gov.sg/media/docs/default-source/e-tax/tax-exemption-for-foreign-sourced-income285e5d43d6af4001b3ce35da1e9005b5.pdf); [Section 13W e-Tax Guide](https://www.iras.gov.sg/docs/default-source/e-tax/etaxguide_certainty-of-non-taxation-of-companies-gain-on-disposal-of-equity-investments.pdf?sfvrsn=ceb9a99_18); [Dividends](https://www.iras.gov.sg/taxes/individual-income-tax/basics-of-individual-income-tax/what-is-taxable-what-is-not/dividends)
- UAE: [General Corporate Tax Guide](https://tax.gov.ae/DataFolder/Files/Guides/CT/CT%20General%20Guide%20-%20EN%20-%2010%2009%202023.pdf); [Exempt Income: Dividends and Participation Exemption](https://tax.gov.ae/Datafolder/Files/Guides/CT/CT%20-%20Exempt%20Income%20-%20Dividends%20and%20Participation%20Exemption%20-%2016%2010%202023.pdf); [Federal Decree-Law No. 47 of 2022](https://tax.gov.ae/Datafolder/Files/Legislation/Corporate%20Tax/CT%20law%20final/Federal%20Decree-Law%20No.%2047%20of%202022%20-%20For%20publishing.pdf)
- United Kingdom: [Corporation tax rates](https://www.gov.uk/government/publications/rates-and-allowances-corporation-tax/rates-and-allowances-corporation-tax); [INTM653010](https://www.gov.uk/hmrc-internal-manuals/international-manual/intm653010); [INTM650000](https://www.gov.uk/hmrc-internal-manuals/international-manual/intm650000); [Marginal Relief for Corporation Tax](https://www.gov.uk/guidance/corporation-tax-marginal-relief); [CG53072](https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg53072); [CG53078](https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg53078); [CG53106](https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg53106); [MTT11010](https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt11010)

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> licensed professional before relying on them.

## Today's figures and who stands behind this skill

This file is an AI skill (tax rules your AI follows) from OpenAccountants, copied on 2026-10-05. Rates, thresholds and deadlines change. For the current version of this skill, its official sources and the named accountant (if any) who stands behind it, call `get_skill` with slug `family-holding-company-location-compared` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/family-holding-company-location-compared. If neither is available, confirm every figure against the official source pages cited above before relying on it.