Grundy, Milton: From the archive - October 2011

From the Archive – October 2011 by Milton Grundy
Of all the topics discussed at ITPA meetings, the holding company is the most frequent. At the very first meeting of the Association, in Amsterdam in 1975, Robert van der Water introduced his audience to the (then largely unknown) Dutch concept of the “participation privilege”. And now if you search “holding” in the Summaries section of the website, you will find no fewer than 59 entries!

What in English is called a “holding company” and in some foreign languages a “holding” (or – to the amusement of English-speakers) a “oldin” is primarily a European concept, but it is also to be found elsewhere – notably in Hong Kong (see e.g. Michael Olesnicky, Hong Kong 2007), in Labuan (see Frederik van Tuyll, Hong Kong, 1999 ), and in Mauritius and Singapore (see Philip Baker and David Chong, Hong Kong 1999). The holding company is a creature of the legislature: unlike many structures familiar to ITPA members, it is actually intended to confer benefits on the taxpayer. (The exception to this rule is Hong Kong, which has just found itself with holding companies, rather like the Bourgeois Gentilhomme found himself speaking prose.)

No better introduction to the European aspect of the subject could be found than Francis Hoogewerf‘s presentation in Amsterdam in 2005. He outlines the benefits of holding companies in 13 countries in the European Union. Later speakers have given separate consideration to many of these – Werner Heyvaert to Belgium (Geneva, 2010), Peter Economides to Cyprus (Cyprus, 2008), Gabor Szabo to Hungary (Vienna, 2007), Chris Curmi to Malta (Barcelona, 2008), Leo Neve to the Netherlands (Vienna, 2007) and Martin Palmer to the United Kingdom (Amsterdam, 2010). Francis Hoogewerf himself returned to what he called “The Big Four” – Cyprus, Malta, Luxembourg and the Netherlands – in Venice in 2010, and Erich Baier will consider Austria in some detail in Luxembourg later this month.