Holding company: which country to choose? Comparison of 9 jurisdictions, with dated and sourced figures

How to read this comparison

Many comparisons line up rates and declare a winner. That is not our method. We compare eight countries on verifiable criteria, with dated and sourced figures, and we flag what we could not confirm rather than guess it. Each country has its own detailed page.

One point outweighs everything else for a reader with ties to France: the holding company's country does not change your personal tax. If you remain a French tax resident, dividends distributed to you are taxable in France, whatever the holding company's country.

The six criteria that matter

1. The final shareholder's residence, which determines personal tax.
2. The treatment of shareholdings: holding threshold, period, conditions on the subsidiary.
3. Withholding taxes on outgoing dividends.
4. The treaty network with the subsidiaries' countries.
5. The substance required and its cost.
6. Banking access and the reputation of the jurisdiction.

The table

The "not published" mention flags a figure we could not confirm (the threshold of the Dutch exemption, which is being amended): we prefer a blank to an approximation. The other thresholds come from foreign firms and administrations, dated in our database.

Reading through the lens of the French tax authorities

The privileged tax regime of article 238 A of the CGI compares the tax actually borne with half of the French tax, i.e. a comparison threshold of 12.5 %verified on 12/10/2026 against the rate of 25 %verified on 09/10/2026. For guidance only:

The comparison actually concerns the tax effectively borne, not just the headline rate: this table is a benchmark, not a classification. For the detail of the mechanisms, see holding company and the French tax authorities. As for the French list of non-cooperative states, neither Andorra nor the eight other countries appear on it at the date of the order of 15 April 2026.

Which country for which profile?

• Andorran-resident shareholder with foreign subsidiaries covered by treaties: the Andorran holding company is often coherent, provided there is substance. See the holding company in Andorra.
• Group with subsidiaries in the European Union and a need for a solid banking image: Luxembourg, the Netherlands or Cyprus deserve examination, with the corresponding substance.
• Group operating in Asia: Singapore.
• Entrepreneur based in the Emirates: Emirati holding company, with free zone and substance.
• French resident who is not moving: the French holding company, under the parent-subsidiary regime, is often safer than a foreign holding company.

This is not personalised advice: each case depends on the facts.

What we do not do

We do not publish a general ranking of countries, because a ranking without a profile makes no sense, and we do not publish a figure we could not cross-check. The cells still empty will be filled in as verifications progress.

Going further

• Holding company in Andorra: complete guide
• Participation exemption in Andorra
• Holding company and the French tax authorities
• The holding company simulator
• Let's talk about your case