International holding structures: are they structurally sound?

With the backdrop of the continually changing global tax landscape, there are a host of international tax issues and complexities associated with corporate holding structures. International tax legislation is evolving quickly, particularly with regards to three key areas of focus for holding structures, being: (i) corporate residence; (ii) a top down approach to taxation and (iii) access to a double tax treaty network. Recent legislative changes are impacting typical group holding structures with issues compounded by the fact that groups are dealing with these changes during a global pandemic and in light of the UK’s departure from the EU single market. With more changes on the horizon, it’s important that holding structures are reviewed and if necessary adapted in order to be structurally sound.