Holding companies.

Corporate vehicles placed where they serve ownership, treaty access and substance.

What it is

What they do.

A holding company sits above an asset, or a group of them, owning what would otherwise be held directly. Used well, it can simplify ownership, open access to treaty relief, ring-fence risk, and give a family or business a single point through which to hold and pass on its interests.

The value is in where it sits and how it is run. We advise on the jurisdiction, the substance it needs to be respected, and how it fits the structures around it — then instruct the agents who form and administer it. We advise on the design; we are not the corporate service provider.

How we advise

Jurisdiction and substance

Placing the company where it earns treaty access and meets the substance the rules require.

Ownership and control

Designing the share and governance structure so control sits where it should.

Treaty and withholding access

Using the right location to manage withholding tax on cross-border flows.

Fit with the wider plan

Positioning the company beneath a trust or foundation, or above operating assets, as the plan needs.

Important information

The basis on which we advise.

This page is general in nature and does not constitute tax, legal or financial advice. Advice is given only under a formal engagement, on the basis of your specific circumstances.

ORA Black advises on the design, selection and coordination of structures; it does not act as trustee, foundation council member or administrator, and does not hold client assets. Fiduciary, formation and administration services are provided by appropriately licensed and regulated providers. Where regulated financial services are required, these are provided through ORA Black’s partnership with NEBA Private Clients.

Discuss your position in confidence.

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