Insights on EU Corporate Structuring

Why reduced withholding tax rates fail in practice, including beneficial ownership, PPT and substance issues in cross-border structures.

How Dutch and Luxembourg structures are used in practice within international corporate groups.

Typical ownership frameworks used to manage subsidiaries and capital flows across Europe.

Corporate tax rules, participation exemption and dividend treatment in holding structures.

How governance, decision-making and substance affect treaty access and tax position.

How Dutch entities are used in acquisitions, joint ventures and transaction structures.

Role of Luxembourg entities in organising ownership, financing and control within groups.

Overview of participation exemption rules across major European jurisdictions.

How the Principal Purpose Test is applied in cross-border tax planning.

Typical structures used to manage subsidiaries, capital flows and control across Europe.

How beneficial ownership is interpreted and tested for treaty access in practice.

How the three jurisdictions are used in practice, including holding roles, tax treatment, substance and structuring logic.

Where Luxembourg works in practice and where structures fail under tax and substance rules.

How Luxembourg is used by US groups for holding, investment and treaty positioning within EU structures.

How LOB and PPT apply in practice and why passing one test is not sufficient for treaty access.

When and why US companies introduce Luxembourg into their European structures and what changes at that stage.

Step-by-step setup of a Luxembourg holding company for US groups, including structure, governance and tax alignment.