Holding : an attractive tax regime

The Parent-Subsidiary regime

A tax option that sets up a tax exemption of 95% on dividend received

Tax rate :

• However a fixed rate of the remaining is liable to the corporate income tax at standard rate (33%)
• The effective taxation rate is limited to 1,67%

Requirements :

• Parent company must be subject to corporate tax (standard rate)
• Parent company must hold at least 5% (capital and voting rights) of it’s subsidiary during at least 2 years
• Subsidiary must be subject to corporate tax

Exemption of the capital gains made on sale of shares

Tax advantage :

• Tax exemption on the gains from the sale of equity shares. A fixed rate of 12% must be reintegrated to the taxable income
• Effective taxation rate limited to 4%

Requirements :

• The equity shares held must be at least 5% of the capital
• The equity shares must have been owned for more than 2 years