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Real Estate (Inv. Prop.)

Amicorp Netherlands B.V.

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Amicorp Netherlands B.V.

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All Amicorp Group products are provided through Amicorp Netherlands. Some principal structures routed through The Netherlands include: Holding Structures (A Netherlands intermediate holding company holds shares in a subsidiary company located outside The Netherlands. Significant reductions in the applicable Netherlands tax on income result because no Netherlands corporate income tax is levied on dividends received or on capital gains realized from the (partial) sale of shares, given certain conditions (e.g., participation exemption qualification).), Finance Structures (Intra-group financing (i.e., internal leveraging) can be achieved through an intermediate Netherlands finance company. This company borrows monies from internal and/or external sources for re-lending to its lower tiered group companies. Netherlands taxes on the interest received and paid with respect to the loans can frequently be reduced to nearly zero as interest paid can be deducted from interest received. Only a (small) spread is regarded as taxable income in The Netherlands.), Real Estate Structures (Holding of Real Estate is often structured through a Netherlands double entity (parent-subsidiary) structure. In this structure, real estate is both held and managed by The Netherlands subsidiary. When the real estate is to be sold, the shares of the Netherlands subsidiary (holding the real estate) are sold. Proceeds from the shares sold in the subsidiary are tax-exempt in the holding company due to participation exemption.), Royalty Structures, Consultancy and Agency Structures

Overview:

The most significant international tax features of the Netherlands include:

   A large network of double income taxation treaties and the EU Parent-Subsidiary Directive. These can reduce withholding tax rates to zero on dividends, interest and royalties paid to a Netherlands holding company.
   Significantly reduced withholding rates on dividends paid from a Netherlands holding company to its parent company. The Netherlands does not levy withholding tax on the distribution of interest and royalties.
   Exemption from Dutch corporate income tax under the participation exemption on dividends received and capital gains realized from a qualifying shareholding.

These advantages play a powerful role in creating and managing holding, financial, royalty, and real estate structures, among others.

Amicorp Netherlands offers all Amicorp Group services.

For more information about structuring through the Netherlands and the services of Amicorp’s Netherlands office, please see the specialized Amicorp brochure.

Languages spoken: Dutch, English, Russian, Turkish, Italian and Spanish.

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