Best approach for holding

[Houdini]

Marzio said:
UK holding.

No WHT on dividends, common law, cheap to manage, access to banks, no questions asked by banks when wiring to holding unlike UAE, outside of EU.
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Not bad, sums it all nicely up, I get a picture of interest for such setup in other situations not only for a France trading company.

With easy banking you mean EMI's right ?

 

[JustAnotherNomad]

oa13 said:
scenario 1
i have company A in france
my personnal tax residence is france
i pay corporate tax in france for company A
i create holding company B in UK as non resident
Company B invests in stocks
Company B pays corporate tax in Uk
i pay tax in france for any dividend i receive from company B
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Both your scenarios 1 and 2 are very likely to be considered CFCs in France.
You need to have a valid reason (saving taxes doesn't count) for not using a French holding company and you will need substance (office, employees) in the other country.
There is lots of legislation in place to make this very difficult to work out.
You should strongly consider moving somewhere else.

 

[myshufflemix]

without substance you can't save any taxes anywhere any longer, make sure to secure substance.