Indian Outbound Tax Implications involving Dutch & Swiss Holding Companies

Course Duration:
225 Minutes (three episodes of 75 minutes each)

Module Background:
As you are aware, the international tax scenario is rapidly changing whereby there are multiple anti-abuse measures brought in by not only OECD but even individual countries. While India has already introduced a few measures like GAAR, POEM, etc – aided by MLI coming into force from 2020, even the countries which were previously a preferred choice for a holding company are adopting substance regulations. Pertinently, some of these countries have embraced more internationally acceptable ways in order to incentivize MNCs.

Against this backdrop, while India’s recently adopted dividend taxation regime is generally beneficial for inbound investment, it is disadvantageous for outbound investments, despite the pass-through benefit granted u/s 80M. From an international perspective, in countries such as the Netherlands, a recent amendment in the Dutch law includes the possibility of claiming exemption on the WHT for dividend. As far as Switzerland is concerned, though it has recently adopted massive tax reforms, it has eliminated some significant benefits such as the holding company regime.

Thus, all these measures warrant a re-look w.r.t existing structures vis-à-vis adoption of an appropriate outbound strategy, so as to evaluate (i) whether the same have turned risky- and if so, what are the options?, as also, (ii) whether the structures are now inefficient and the possible ways to optimize the same. In this regard, in an effort to apprise our subscribers on the changing scenario of outbound structures, Taxsutra, in association with K. C. Mehta & Co. has unveiled a module on “Outbound Tax Implications – Insights into Changing Tax Scenarios in India, Netherlands & Switzerland.” In this special module, Mr. Milin Mehta & Mr. Suril Mehta from K C Mehta & Co. have elaborated on the changing international tax scenario using a case study approach, in conjunction with Mr. Bas Veldhuis from Prudence Tax & Consultancy (Dutch Tax Practitioner) and Mr. Thomas Linder from MME (Swiss Tax Practitioner).
This module comprises of the  following episodes:

Episode 1: Outbound Tax Implications involving a Dutch Holding Company.

Episode 2: Outbound Tax Implications from an Indian Perspective – Strategies and Anti-abuse Provisions

Episode 3: Outbound Tax Implications involving a Swiss Holding Company