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01 — Legal

Foreign holding company structures

Centralize ownership, protect assets and prepare your business for international growth.

We help business owners, founders, investors and family groups create foreign holding company structures for shares, subsidiaries, intellectual property, real estate, investment assets and international business operations.

A holding company can provide a clearer ownership framework, support tax-efficient dividend planning, separate operating risks from strategic assets, improve investor confidence and make the business easier to manage, finance, transfer or sell.

Our work covers jurisdiction selection, holding structure design, company formation, subsidiary planning, tax coordination, corporate governance, banking readiness, reporting and ongoing administration.

A holding structure helps separate ownership from operations

As a business grows, one operating company may no longer be enough. A foreign holding company can be used to own:

  • Shares in operating companies
  • Subsidiaries in several jurisdictions
  • Intellectual property
  • Real estate
  • Investment assets
  • Financing companies
  • Family business assets
  • Strategic reserves
  • Other high-value assets

This allows the client to separate day-to-day business risks from long-term ownership and control.

Six benefits of a properly designed holding structure

From centralized ownership to succession planning — the outcomes a well-designed holding structure supports.

Centralized ownership

A holding company can own several subsidiaries or assets under one parent structure. This makes the ownership chain clearer and easier to manage.

Asset protection

Strategic assets can be separated from operational risks, commercial disputes, creditor pressure or local jurisdictional instability.

Dividend and profit distribution planning

A holding structure can help organize dividends, intercompany payments and profit repatriation in a more predictable and tax-aware way.

Investment readiness

Investors, lenders and buyers often prefer a clean holding structure with clear ownership, reporting and governance.

IP ownership

A dedicated holding company can own software, trademarks, patents, licences, brands and other intellectual property used by operating companies.

Succession and family planning

A holding structure can support inheritance planning, transfer of control, family governance and long-term continuity of business ownership.

When clients ask for a holding company

Typical moments where a holding structure removes risk and creates room to grow.

01

The business has subsidiaries in several countries

A holding company can centralize ownership and simplify governance, reporting and dividend planning.

02

The owner wants to protect strategic assets

Real estate, IP, shares or investment assets can be separated from operating companies that carry commercial risk.

03

The company is preparing for investors

A holding structure may make the business easier to understand, value, finance and invest in.

04

The business needs an IP holding company

Software, trademarks, brands and licences may need to be owned by a dedicated company and licensed to operating entities.

05

The current ownership structure is outdated

A structure created years ago may no longer match tax rules, banking expectations, substance requirements, beneficial ownership rules or investor expectations.

06

The founder is planning relocation or succession

Changes in personal tax residence, family planning or inheritance goals may require a more sophisticated ownership structure.

The building blocks of a holding group

Six types of company, combined to fit the client's operations, assets and long-term plans.

Parent holding companies

Companies that own operating subsidiaries, asset-holding companies, IP companies or investment vehicles.

Sub-holdings

Intermediate companies used to separate business lines, countries, assets, partners or investor groups.

Operating subsidiaries

Companies that conduct commercial activity, sign contracts, employ staff, invoice clients or operate locally.

IP holding companies

Companies that own and license software, trademarks, brands, patents, platforms, databases and other intellectual property.

Asset-holding companies

Companies used to own real estate, vehicles, yachts, aircraft, investment portfolios or valuable movable property.

Investment and treasury companies

Companies used for financing, shareholder loans, group treasury, investment activity or capital allocation.

Our holding company structuring work

From structure analysis through to ongoing administration — covering jurisdictions, design, formation, tax, substance and banking.

01

Current structure analysis

We review the client's existing companies, shareholders, directors, assets, contracts, banks, payment flows and tax position. This helps identify:

  • Ownership risks
  • Tax inefficiencies
  • Banking issues
  • Reporting gaps
  • Weak governance
  • Direct asset exposure
  • CFC risks
  • Substance concerns
  • Investor due diligence issues
02

Jurisdiction selection

We compare jurisdictions for the holding company based on legal, tax and practical factors. This may include:

  • Corporate tax treatment
  • Dividend taxation
  • Withholding tax
  • Double-taxation treaties
  • Controlled foreign company rules
  • Substance requirements
  • Beneficial ownership disclosure
  • Corporate law flexibility
  • Investor familiarity
  • Banking access
  • Audit and reporting obligations
  • Cost of maintenance
  • Reputation of the jurisdiction

We do not select a holding jurisdiction based only on tax rates. The structure must work for banks, auditors, tax authorities, investors and counterparties.

03

Holding structure design

We design the ownership structure around the client's commercial and private goals. This may include:

  • Parent company
  • Subsidiaries
  • Sub-holdings
  • IP company
  • Asset-holding company
  • Financing company
  • Management company
  • Investor or shareholder structure
  • Dividend routes
  • Intercompany agreements
  • Ownership chart
  • Governance model

The structure should be understandable, documented and commercially justifiable.

04

Company formation and administration

We coordinate the formation and administration of the holding company and related entities. This may include:

  • Incorporation
  • Registered office
  • Corporate secretary
  • Directors and shareholders
  • Constitutional documents
  • Corporate registers
  • Initial resolutions
  • Tax or business registration
  • Annual renewals
  • Registered agent coordination
  • Local provider communication
05

Subsidiary and group setup

If the client already has operating companies, we help plan how they may be owned by the holding company. If the structure is new, we help create the group from the beginning. This may include:

  • Share transfers
  • Capital contributions
  • Incorporation of subsidiaries
  • Intercompany agreements
  • Management agreements
  • IP licence agreements
  • Shareholder approvals
  • Corporate restructuring documents
  • Registry updates
06

Tax and dividend planning

A holding structure must be tax-aware from the start. We coordinate analysis of:

  • Dividend flows
  • Withholding tax
  • Treaty access
  • Beneficial ownership
  • Capital gains
  • Interest and royalties
  • CFC rules
  • Substance requirements
  • Transfer pricing
  • Reporting obligations
  • Audit requirements
  • Profit repatriation

The aim is to create a lawful and defensible structure, not an artificial tax arrangement.

07

Substance and governance

Modern holding structures often require real governance and economic logic. We help plan and document:

  • Decision-making process
  • Board meetings
  • Director roles
  • Office or local presence where needed
  • Accounting records
  • Group policies
  • Contracts
  • Minutes and resolutions
  • Management substance
  • Business purpose
  • Corporate control

This reduces the risk that the holding company is treated as a purely artificial or unsupported structure.

08

Banking and compliance readiness

Banks and payment providers often review holding structures carefully. We help prepare:

  • Ownership chart
  • Corporate documents
  • Business model explanation
  • Source-of-funds materials
  • Source-of-wealth materials
  • Dividend and payment flow logic
  • Tax position summary
  • Group structure explanation
  • Contracts and supporting documents
  • Compliance file

This makes the structure easier to explain during bank onboarding or review.

09

IP holding and licensing

Where the group owns valuable intellectual property, we help structure IP ownership and licensing. This may include:

  • Software rights
  • Trademarks
  • Patents
  • Brands
  • Databases
  • Licences
  • Royalty arrangements
  • IP assignment documents
  • Licensing agreements
  • Open-source or third-party materials review
  • Tax and transfer-pricing coordination

This is especially important for SaaS, fintech, crypto, digital platforms, media businesses and technology companies.

10

Ongoing support

A holding company must be maintained after incorporation. We support:

  • Annual reporting
  • Audit coordination
  • Corporate renewals
  • Changes in shareholders or directors
  • Subsidiary updates
  • Dividend documentation
  • Group restructuring
  • Liquidation or consolidation of entities
  • Bank review responses
  • Investor due diligence
  • Tax adviser coordination

How an engagement runs

Seven structured stages from initial consultation through to ongoing maintenance.

01

Initial consultation

We review the client's business, assets, current companies, ownership chain, tax residence, banking needs and long-term goals.

At this stage, we determine whether a holding company is appropriate and what structure may be required.

02

Structure and jurisdiction analysis

We compare possible holding jurisdictions and evaluate the legal, tax, banking, reporting and compliance implications.

This includes reviewing DTT, CFC, substance, AML/KYC, beneficial ownership and reporting considerations.

03

Holding structure design

We create a practical structure showing the parent company, subsidiaries, sub-holdings, asset companies, IP companies and payment flows where relevant.

The result may include an ownership chart, implementation roadmap and list of required documents.

04

Company formation

We coordinate incorporation of the holding company and any required subsidiaries or related companies.

This includes corporate documentation, registered office, corporate secretary, directors, shareholders, registers and initial resolutions.

05

Restructuring and asset transfer

Where needed, we help transfer shares, IP rights, assets or intercompany relationships into the new holding structure.

This may require local legal, tax, accounting or registry coordination.

06

Banking, tax and reporting setup

We help prepare the structure for bank onboarding, tax registration, accounting, reporting calendar, audit coordination and compliance review.

07

Ongoing maintenance

We support annual renewals, reporting, governance, changes in ownership, dividend documentation, investor due diligence and future restructuring.

Built for owners thinking about long-term structure

From founders separating operations from ownership to family offices planning succession.

Business owners and founders

For clients who need to separate ownership from operations and create a clearer long-term structure.

International business groups

For companies operating through several entities, jurisdictions or business lines.

Technology and IP-driven businesses

For companies that need to hold software, platforms, brands or licences separately from operating risk.

Investors and family offices

For clients holding shares, real estate, investment assets or family business interests.

Companies preparing for investment or sale

For businesses that need a clean ownership structure before due diligence, financing or M&A.

Holding-structure work that goes beyond incorporation

Four principles guide every holding company engagement.

01

Cross-border structuring experience

Holding structures usually involve several jurisdictions, tax systems, banking relationships and reporting regimes. We connect these elements into one practical structure.

02

Practical implementation

We help not only with the structure, but also with company formation, documentation, banking readiness, reporting and ongoing administration.

03

Tax-aware, compliance-first approach

We design holding structures that can be explained to banks, auditors, tax authorities, investors and regulators.

04

Long-term planning

We consider not only the immediate setup, but also future growth, dividends, investor entry, succession, sale and restructuring.

Expected outcome

A documented holding framework, ready to grow with the business

By the end of the process, the client receives a structured and documented foreign holding framework. This may include a selected holding jurisdiction, an incorporated holding company, subsidiaries or a sub-holding structure, an ownership chart, corporate records, shareholder and director documentation, intercompany agreements, a dividend and tax planning roadmap, a banking support file, substance and governance recommendations and a reporting and maintenance calendar. The result is a holding structure that can support business expansion, asset protection, tax planning, investor readiness and long-term ownership control.

Compliance note

Lawful, transparent holding structures

Foreign holding structures must comply with applicable corporate, tax, reporting, AML, sanctions, beneficial ownership, substance, exchange control and anti-avoidance rules. We do not assist with sham structures, false ownership records, tax evasion, sanctions circumvention, concealment of assets, fraudulent transfers or structures intended to mislead banks, courts, tax authorities, creditors or regulators. Where a proposed structure creates legal, tax, sanctions, creditor, family law or reputational risk, we may recommend a safer alternative or decline the matter.

Need to create a foreign holding company?

Tell us what assets or companies the holding structure should own, where the owners are tax resident, which jurisdictions are involved and what you want the structure to achieve. We will review the legal, tax, banking and compliance issues and propose a practical holding structure.

International legal advisory for founders, investors, and businesses operating across borders.

Contact

Office 2001-72 Prime Tower,
Business Bay,
Dubai, UAE

+971 4 000 0000

Mon–Fri, 10:00–19:00 (GMT+4)