Where to put the family holding company: nine countries compared

Figures are for tax year 2026. This Guide compares Malta, Cyprus, Ireland, Luxembourg, the Netherlands, Switzerland, Singapore, the United Arab Emirates and the United Kingdom as the home of a family holding company. A family holding company here means a company owned by family members that holds shares in one or more operating companies, receives their dividends and sometimes sells a stake. For each country it gives the headline corporate rate, the exemption for dividends and gains from subsidiaries with its conditions, the tax on dividends paid out to the family, and the year each rule applies from. Every figure sits in a table that names its official page. Where an allowed official page does not print a figure, the Guide says "not printed on an allowed page" instead of guessing. Pages were read on 4 October 2026.

This Guide is a first sort. It does not decide residence of the company, CFC exposure of the family member at home, or substance. For those, see mt-company-residence-and-substance and cfc-and-substance-rules-compared. For Malta in depth, see mt-holding-company-participation-exemption. For trusts and foundations as the top of the structure, see trusts-vs-foundations-by-country.

The method, step by step

1. Fix the facts first: where each family member is tax resident, where the operating subsidiaries are resident, the size of each holding, the date each holding was acquired, and whether each subsidiary trades or mainly holds investments or property. Every exemption below turns on these. Use the questions in "Ask the client first".
2. For each candidate country, test the dividend exemption on its own conditions (holding size, holding period, subject-to-tax or anti-abuse test). The country sections below give each test with its law and link, for example Malta's article 12(1)(u) in the Income Tax Act, Cap. 123.
3. Test the gains exemption separately. In most of these countries the gains test differs from the dividend test (the UK requires a trading subsidiary, Singapore requires a bigger stake held longer, Luxembourg has a higher acquisition-cost alternative). See the UK CG53072 and Singapore's section 13W e-Tax Guide.
4. Work out what happens when money leaves the holding company for the family: the outbound dividend withholding or shareholder-level charge, for individuals and for companies. Malta works through refunds to the shareholder under article 48 of the Income Tax Management Act, Cap. 372 instead of a withholding tax.
5. Check the family member's home country. A low-taxed holding company may be taxed in the shareholder's own country under its CFC rules, whatever the holding country charges. See cfc-and-substance-rules-compared.
6. Flag Pillar Two only if the whole group has consolidated revenue above the threshold in two of the four periods before (see the UK table below) (MTT11010). Family groups rarely do.
7. Run the worked hypothetical in "Worked hypothetical" with the client's own numbers, and record which condition each answer depends on.

Comparison at a glance

Each value in this table is repeated from the sourced country table further down. Read the country section before relying on a row: every exemption has conditions, and failing one usually means the full rate applies.

Country	Headline corporate rate 2026	Dividend exemption: holding and period	Gains exemption: holding and period	Outbound dividend tax
Malta	thirty-five cents on every euro (article 56(6)); elective fifteen cents, final, no refund to the shareholder (L.N. 188 of 2025)	Participating holding (at least five percent of equity, or EUR 1,164,000 held 183 days, among other routes) plus anti-abuse test	Same participating holding test; restricted for Malta-resident investees (art. 12(1)(u) proviso)	Refunds to the shareholder (six-sevenths, five-sevenths, two-thirds or all) on taxed-account dividends; fifteen per cent deducted on untaxed-account dividends to a "recipient" (article 61: mainly Malta-resident persons other than companies, and non-residents controlled by Malta ordinarily resident and domiciled individuals)
Cyprus	15%	All dividends exempt from corporate tax, with one exclusion (dividend deductible for the payer)	All gains on "titles" (shares and similar) exempt	5% SDC for resident and domiciled individuals on 2026+ profits; 5% or 17% to some non-resident companies
Ireland	12.5% trading; 25% non-trading	At least five per cent for 12 months, foreign subsidiary (from 1 January 2025)	At least 5 per cent for 12 months, trading test	25% DWT, with exemptions for qualifying non-residents
Luxembourg	16% (top band); 23.87% combined in Luxembourg City	10% or EUR 1,200,000, held 12 months	10% or EUR 6,000,000, held 12 months	15% withholding
Netherlands	19.0% up to EUR 200,000; 25.8% above	At least 5% (participation exemption)	Same participation exemption	15% dividend tax
Switzerland	8.5 Prozent federal only, plus cantonal tax	Participation reduction (not an exemption), 10 Prozent or one million francs	10 Prozent held at least one year	35% withholding tax
Singapore	17%	Singapore dividends one-tier and not taxable; foreign dividends exempt if conditions met (headline rate at least 15%)	At least 20% held 24 months (section 13W)	No tax on one-tier dividends in the shareholder's hands
UAE	9% above AED 375,000	5% or AED 4 million, 12 months, subject to tax at 9% or more	Same participation exemption	0% withholding tax
United Kingdom	25% main rate; 19% small profits rate (limits shared with associated companies; see the UK section)	Distribution exemption (exempt classes, Part 9A of the Corporation Tax Act 2009)	Substantial shareholdings exemption, at least 10% for 12 months, trading investee	Not printed on an allowed page

Pillar Two: a one-line flag only. It applies to groups with consolidated revenue at the threshold in the UK table (EUR 750 million). Families rarely reach it.

Malta

Malta taxes a company at a flat rate on chargeable income and then refunds part or all of that tax to the shareholder when the profits are paid out as a dividend. A holding company can also take a participation exemption instead.

Item	Value	Note (verbatim from the page)
Source	all figures below	https://legislation.mt/eli/cap/123/eng/pdf
Company rate, article 56(6)	thirty-five cents on every euro	"The tax shall be charged at the rate of thirty-five cents (0.35) on every euro of the chargeable income of every - ... (a) company"
Participating holding, route (a)	at least five percent of the equity shares	"a company holds directly at least five percent of the equity shares of a company"
Participating holding, route (e)	EUR 1,164,000	"a minimum of one million, one hundred and sixty-four thousand euro (€1,164,000)" held "for an uninterrupted period of not less than 183 days"
Dividend anti-abuse, limb (i)(2)	15%	"it is subject to any foreign tax of at least fifteen per cent (15%)"
Dividend anti-abuse, limb (i)(3)	50%	"it does not have more than fifty per cent (50%) of its income derived from passive interest or royalties"
Dividend anti-abuse, limb (ii)(2)	5%	"subject to any foreign tax at a rate which is not less than five per cent (5%)"
Tax deducted from an untaxed dividend paid to a recipient, article 62(1)	fifteen per cent	"deduct therefrom tax at a rate of fifteen per cent."

Rules, from article 12(1)(u) of the Income Tax Act:

• WHO: a company registered in Malta that holds a "participating holding". The definition in article 2(1) has several routes, any one of which is enough (OR): at least five percent of the equity shares with at least five percent of any two of votes, distributable profits and assets on a winding up; an option to buy the rest of the shares; a right of first refusal; the right to sit on or appoint a director to the board; an investment of at least the amount in the table held for an uninterrupted period of not less than 183 days; or a holding for the furtherance of its own business that is not trading stock.
• WHAT: income or gains from the participating holding, and gains on its transfer, are exempt where the company has not shown them as chargeable income in its return. The company may instead declare them; the shareholder may then claim a refund (below).
• DIVIDEND CONDITIONS: for a dividend from a participating holding acquired on or after 1 January 2007 (and, from 1 January 2011, also one acquired before), the exemption applies only if the subsidiary meets ANY ONE of: resident or incorporated in the EU; subject to foreign tax of at least the 15% in the table; not more than 50% of its income from passive interest or royalties. If it meets none of these, BOTH of these must hold: the holding is not a portfolio investment, AND the subsidiary or its passive interest or royalties were subject to foreign tax of at least 5%.
• EXCLUSION: the exemption does not apply to income from a participating holding in a body resident in a jurisdiction on the EU list of non-cooperative jurisdictions for at least three months in the year before the year of assessment, unless the company proves the body has sufficient significant people functions there.
• GAINS: the dividend conditions above apply to dividends only. A separate proviso covers a participating holding "in a company or in a partnership, EEIG, other body of persons or collective investment scheme ... that is resident in Malta", and holdings that hold such interests directly or indirectly. Gains on those "shall only qualify for the exemption if such gains or profits would have been exempt in terms of sub-paragraph (ii) of paragraph (c) had the transfer of the holding been made by the beneficial owner". Article 12(1)(c)(ii) exempts gains of "any person not resident in Malta". Where there are several beneficial owners, the exemption applies only to the exempt owners' share.

Item	Value	Note (verbatim from the page)
Source	all figures below	https://legislation.mt/eli/cap/372/eng/pdf
Standard refund, article 48(4A)(a)	six-sevenths	"may claim a refund of six-sevenths of the Advance Company Income Tax pertaining to those profits"
Passive interest or royalties, or a participating holding dividend that fails the anti-abuse test	five-sevenths	"the rate of refund shall be of five-sevenths of the said Advance Company Income Tax"
Profits from a participating holding distributed out of the foreign income account, article 48(4)(b)	all of the Malta tax	"a claim may be made for a refund of all of the Malta tax paid in respect of those profits"
Foreign income account profits, article 48(4)(a) (the route where the company claimed double taxation relief, since article 48(4A) is then barred)	two-thirds	"may claim a refund of two-thirds of the Malta tax paid by the company"

• WHO claims: the shareholder who receives the dividend, and only once registered for the purpose ("provided that such person is for such purpose registered in such manner as may be prescribed").
• NO REFUND under article 48(4A) on foreign income account profits where the company claimed double taxation relief; a two-thirds refund under article 48(4)(a) may then be claimed.
• CAP: the refund never exceeds the tax the company actually paid on the profits distributed.
• NOT SETTLED for Malta-resident individuals: article 12(1)(c)(iii) of the Income Tax Act exempts some taxed-account dividends paid to individuals and ties that exemption to the refund bar in the last proviso to article 48(1) of Cap. 372. How that interacts with the article 48(4A) refund was not settled from the text. Refer before telling a Malta-resident individual shareholder to rely on a refund (see mt-holding-company-participation-exemption).
• The full refund under article 48(4)(b) for participating holding dividends carries the same anti-abuse conditions as the exemption.

Elective final tax. L.N. 188 of 2025, the Final Income Tax Without Imputation Regulations, lets an entity elect to be taxed "at the rate of fifteen cents (0.15) on every euro of the chargeable income, in lieu of the rate determined in article 56(6)". It applies to income of the fiscal year preceding year of assessment 2025 and later years. Once elected, the entity cannot switch back before the end of a five-year period, and after switching back the ordinary rules apply for at least five consecutive years of assessment. The election is made by notice in the form and by the date the Commissioner sets. The 15-cent tax "shall be final and shall not be available as a credit or set off against the tax liability of any individual or entity, or as a refund to any person" (reg. 3(4)(b)), so no shareholder refund follows it. It "shall in no case be lower than" the ordinary tax "reduced by the amount of refund claimed or claimable in terms of article 48(4) or (4A)" by all shareholders (reg. 3(4)(a)). The taxed profits go to the final tax account (reg. 3(4)(c)). Chargeable income under the election excludes dividends received from profits that are not "allocated to the final tax account of another company registered in Malta" and income already taxed at a final rate (reg. 3(1) proviso). These regulations are S.L. 123.217.

A Malta company paying a dividend out of its untaxed account to a recipient must, on that payment, "deduct therefrom tax at a rate of fifteen per cent." under article 62(1) of the Income Tax Act. Article 61 defines a recipient as, among others, a person, other than a company, resident in "Malta in the year in which a dividend is received by him or by any person on his behalf", and "a non-resident person (including a non-resident company) who is owned and controlled by, directly or indirectly, or who acts on behalf of, an individual who is ordinarily resident and domiciled in Malta". The foreign income account holds profits only "to the extent that they result from taxable income"; which account exempt participation income is allocated to is not settled in one sentence of the Act, so refer that question to a Malta accountant before advising. Dividends from taxed accounts carry the refunds above.

Cyprus

Cyprus raised its corporate rate for 2026 and changed Special Defence Contribution (SDC) on dividends in the same reform. The 15% corporate tax rate below comes from the Tax Department's income tax reform presentation, not from the consolidated law text.

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.gov.cy/media/sites/167/2026/03/2026-%CE%A6%CE%BF%CF%81%CE%9C%CE%B5%CF%84%CE%B1%CF%81%CF%81%CF%8D%CE%B8%CE%BC%CE%B9%CF%83%CE%B7-%CE%A6%CF%8C%CF%81%CE%BF%CF%82-%CE%95%CE%B9%CF%83%CE%BF%CE%B4%CE%AE%CE%BC%CE%B1%CF%84%CE%BF%CF%82.pdf
Corporate income tax rate from 1 January 2026	15%	"Από την 1/1/2026, οι εταιρείες υπόκεινται σε εταιρικό φόρο με συντελεστή ύψους 15%"

The Tax Department's corporate tax page lists dividends ("Μερίσματα Όλα") and gains from the disposal of titles ("Κέρδη που προκύπτουν από τη διάθεση Τίτλων Όλα") as fully exempt from corporate tax. Conditions printed there:

• Dividends: the exemption does not apply where a dividend paid by one company to a Cyprus tax-resident company is deducted from the taxable income of the company paying it. There is no holding percentage or holding period on that page.
• Titles: "shares, debentures, bonds, founders' and other titles of companies or other legal persons", Cypriot or foreign, and rights over them, including options, futures, swaps and units in collective investment schemes.

The SDC figures below come from the Tax Department's presentation of "Ο περί Έκτακτης Εισφοράς για την Άμυνα της Δημοκρατίας (Τροποποιητικός) (Αρ. 4) Νόμος του 2025", in force from 1/1/2026, not from the consolidated law text.

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.gov.cy/media/sites/167/2026/03/EEA-%CE%A6%CE%9A%CE%9A-%CE%9C%CE%95%CE%A4%CE%91%CE%A1%CE%A1%CE%A5%CE%98%CE%9C%CE%99%CE%A3%CE%97-06032026.pdf
SDC on dividends received by individuals	5%	"Άτομα σε ποσοστό 5% (μείωση από το 17%)"
SDC on dividends paid out of profits of tax years up to 2025, received up to 31/12/2031	17%	"Καταβάλλεται ΕΕΑ σε ποσοστό 17% επί των μερισμάτων που λαμβάνονται από εταιρεία κάτοικο της Δημοκρατίας μέχρι και την 31/12/2031"
SDC on foreign dividends received by a Cyprus company, passive and low-taxed payer	5%	"σε ποσοστό 5% επί των μερισμάτων που λαμβάνει από εταιρεία που δεν είναι κάτοικος στη Δημοκρατία"
Passive-activity limb of that test	50%	"επιδίδεται άμεσα ή έμμεσα περισσότερο από 50% σε δραστηριότητες οι οποίες απολήγουν σε εισόδημα από επένδυση"
SDC on dividends paid by a Cyprus company to a non-resident company in a low-tax jurisdiction	5%	"σε ποσοστό 5%, εάν είναι κάτοικος σε δικαιοδοσία με χαμηλό φορολογικό συντελεστή"
Same, non-cooperative jurisdiction	17%	"σε ποσοστό 17%, εάν είναι κάτοικος σε μη συνεργάσιμη δικαιοδοσία"
Shares that count as Cyprus property for capital gains tax	20%	"εάν τουλάχιστον το 20% (αντί του 50%) της αγοραίας αξίας τους προέρχεται από την ακίνητη ιδιοκτησία στη Δημοκρατία"
Deemed distribution: share of 2024 and 2025 profits	70%	"εβδομήντα τοις εκατό (70%) των κερδών της που κτήθηκαν ή προέκυψαν στα φορολογικά έτη 2024 και 2025"
SDC on the deemed distribution	17%	"Η λογιζόμενη διανομή φορολογείται στο 17%."

• Individuals: SDC on dividends is charged on a Cyprus-resident individual who is also domiciled; the presentation states "Διατηρείται το καθεστώς non-dom" (the non-dom regime is kept). Dividends out of profits of tax years up to and including 2025 stay at 17% if received up to 31/12/2031; dividends out of 2026 and later profits are at 5%. Read both rows above together.
• Foreign dividends into a Cyprus holding company: SDC at 5% applies only where the paying company BOTH engages directly or indirectly more than 50% in activities producing investment income AND bears foreign tax lower than 50% of the Cyprus tax burden. Otherwise no SDC is printed for this case.
• Dividends paid to a non-resident company: the new article 3(1)(d) charges SDC on a non-resident company receiving dividends from a Cyprus company, at 5% if it is resident (or incorporated and not resident elsewhere) in a low-tax jurisdiction, and at 17% if in a non-cooperative jurisdiction. If a jurisdiction is on both lists, 17% applies.
• The Tax Department's withholding page for payments to non-residents lists royalties, film rentals and professional and artists' fees. It does not list dividends.
• Property-rich shares: shares of a company that directly holds Cyprus immovable property, or indirectly where at least the 20% in the table of market value comes from it, are "property" for capital gains tax, which is outside the corporate tax exemption for titles. A treaty that taxes only above a 50% value test can override this.
• A Cyprus-resident company is still deemed to distribute part of its 2024 and 2025 profits (rows above); this applies only to profits attributable to a person resident in Cyprus on the deemed distribution date ("εφαρμόζονται μόνο στα κέρδη που αναλογούν άμεσα ή έμμεσα σε άτομο το οποίο ... ήταν κάτοικος της Δημοκρατίας"). It is abolished for profits of 2026 onward ("Κατάργηση της λογιζόμενης διανομής των κερδών των ετών από το 2026 και εντεύθεν").

Ireland

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.revenue.ie/en/companies-and-charities/corporation-tax-for-companies/corporation-tax/basis-of-charge.aspx
Trading income	12.5%	"There are two rates of Corporation Tax (CT): 12.5% for trading income"
Non-trading income (rental, investment) and excepted trades	25%	"25% for: income from an excepted trade ... non trading income, for example rental and investment income"

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.revenue.ie/en/personal-tax-credits-reliefs-and-exemptions/tax-relief-charts/index.aspx
Dividend withholding tax (DWT), 2026	25%	"Tax Rate: Schedule F (WH = Withholding Tax) 25% WH"

• Foreign dividends, participation exemption (section 831B): for a distribution made on or after 1 January 2025, a parent company that holds at least five per cent of the ordinary share capital for a continuous period of at least 12 months, including the date of the distribution, may claim exemption. The subsidiary must be resident in a relevant territory (EU or EEA country or treaty country, not on the EU list of non-cooperative jurisdictions) and not generally exempt from foreign tax. For distributions from 1 January 2026, that status must have held throughout the preceding three years (five years for 2025). From 2026, a "relevant territory" includes a non-treaty country that generally applies a withholding tax on cross-border distributions. Distributions received as trading income and distributions deductible abroad are excluded. The claim covers ALL relevant distributions from ALL relevant subsidiaries for the accounting period: it cannot be made per dividend or per subsidiary, and the alternative is a double tax credit.
• Gains, section 626B: a gain on disposal of shares is not a chargeable gain where the investor company has held a "real" holding of at least 5 per cent for a continuous period of 12 months (the disposal must be while it is a parent or within 2 years after), the investee is resident in an EU state or treaty territory, AND at the time of disposal the investee or the group is wholly or mainly (more than half) trading. The exemption does not apply to shares deriving the greater part of their value from land or minerals in the State.
• Outbound: Irish companies withhold DWT at the rate in the table. A qualifying non-resident can claim exemption by declaration (Form V2B for a company, V2A for an individual). For an individual this means not resident or ordinarily resident in Ireland and resident in an EU or EEA state or treaty country. For a company it includes one resident in such a territory that is not directly or indirectly controlled by an Irish resident. The exemption is not automatic and lasts until 31 December of the fifth year after issue.
• A family-owned Irish company will often be a close company (controlled by five or fewer participators, or by its directors). Part 13 of the Tax and Duty Manuals then applies; its rates are not printed on the pages read for this Guide.

Luxembourg

Item	Value	Note (verbatim from the page)
Source	all figures below	https://impotsdirects.public.lu/fr/az/t/tarif-applicable-collectivites/tarif-collect.html
Corporate income tax (IRC), top band, from tax year 2025	16%	"16% lorsque le revenu imposable dépasse 200.000 euros"

Item	Value	Note (verbatim from the page)
Source	all figures below	https://impotsdirects.public.lu/fr/az/c/charg_fisc.html
Combined IRC, employment fund surcharge and municipal business tax, Luxembourg City, from 2025	23.87%	row "Charge fiscale d'une collectivité au taux d'imposition nominal (A+B+C)", last column "à partir de 2025", printed as 23,87%

Item	Value	Note (verbatim from the page)
Source	all figures below	https://impotsdirects.public.lu/fr/az/r/regi_soc.html
Dividend exemption: minimum holding	10%	"le taux de participation ne descend pas au-dessous du seuil de 10 % ou le prix d'acquisition au-dessous de 1.200.000 €"
Dividend exemption: alternative acquisition price	EUR 1,200,000	same sentence
Gains exemption: alternative acquisition price	EUR 6,000,000	"ne descend pas au-dessous du seuil de 10 % ou le prix d'acquisition au-dessous de 6.000.000 €"

This page was last updated on 9 January 2017.

Item	Value	Note (verbatim from the page)
Source	all figures below	https://impotsdirects.public.lu/dam-assets/fr/legislation/LIR/texte-coordonn-en-vigueur-au-1er-janvier-2026-ver-08052026.pdf
Withholding tax rate on dividends, article 148	15%	"Le taux de la retenue est fixé à 15%."

• The 16% in the first table is the top band of the corporate income tax only. The combined figure is the authority's own example for a company seated in the commune of Luxembourg; other communes differ. The coordinated law text in force on 1 January 2026 carries the same 16% in article 174.
• Dividend exemption (article 166 LIR): a fully taxable resident capital company, or a qualifying permanent establishment, holding directly a participation in a fully taxable resident company, a non-resident company fully subject to a tax corresponding to IRC, or an EU company, is exempt on the dividend where, on the date the income is made available, it holds or undertakes to hold the participation for an uninterrupted period of at least 12 months AND throughout that period the holding does not fall below 10% OR the acquisition price does not fall below the amount in the table. If the 12 months are not reached, the exemption is withdrawn by a corrective assessment.
• Gains: the same holding period and 10% test, with the higher acquisition-price alternative in the table.
• Outbound: the authority's page states that a company paying an exempt participation dividend is, under certain conditions, exempt from withholding. That page (last updated 9 January 2017) prints an older withholding rate; the law in force on 1 January 2026 prints the rate in the last table. Use the law.

Netherlands

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/tarieven_vennootschapsbelasting
Band limit	EUR 200,000	"tot en met € 200.000 19,0% boven € 200.000 25,8%"
Rate up to and including the band limit	19.0%	same
Rate above the band limit	25.8%	same; the page heads the table "De tarieven voor de vennootschapsbelasting in 2026, 2025, 2024 en 2023"

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/deelnemingsvrijstelling/deelnemingen
Participation: minimum holding	5%	"U bent voor ten minste 5% van het nominaal gestorte kapitaal aandeelhouder van een vennootschap"

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/dividendbelasting/als_u_dividend_uitkeert/als_u_dividend_uitkeert
Dividend tax rate	15%	"Het tarief van de dividendbelasting is 15%."

• Participation exemption: where a participation exists (at least 5% of the paid-up nominal capital, among other routes on the page), profits from it are generally exempt. A holding below 5% cannot be a participation, with one exception: a participation of at least 5% held for more than 1 year that falls below 5% keeps the exemption for 3 more years.
• The exemption "is niet van toepassing op een niet-kwalificerende beleggingsdeelneming"; the credit method (deelnemingsverrekening) applies instead. Whether a participation is held as an investment "hangt onder meer af van het oogmerk"; a top holding company with a real management, policy or financing function for the group may not hold it as an investment. A participation whose assets are mostly holdings below 5%, or whose function is mostly group financing, is always a portfolio participation. See Deelnemingsvrijstelling and Wanneer is een deelneming een beleggingsdeelneming?.
• Holding period: none is printed on the page for the basic test.
• Outbound to a Dutch resident individual: the paying company "meestal" withholds the rate in the table on a portfolio dividend.
• Outbound to a company: on a participation dividend (5% or more) to a Dutch company, the company usually applies the withholding exemption. To a company in a country with which the Netherlands has a tax treaty, the exemption applies where "er geen sprake van misbruik" is (there is no abuse). With no treaty, the dividend is not exempt and the company withholds the rate in the table.
• For Dutch corporate tax in full, see nl-corporate-tax.

Switzerland

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.estv.admin.ch/estv/de/home/verrechnungssteuer.html
Withholding tax (Verrechnungssteuer) on investment income	35%	"Der Steuersatz beträgt 35 % auf Kapitalerträgen und Lottogewinnen"

The federal rules come from the Federal Direct Tax Act (DBG), status 1 January 2026. The Act writes percentages as words, so they are quoted here as printed:

• Rate, article 68: "Die Gewinnsteuer der Kapitalgesellschaften und Genossenschaften beträgt 8,5 Prozent des Reingewinns." This is the federal tax only. Cantonal and communal profit taxes come on top and are not covered by this Guide.
• Participation reduction, article 69: the federal profit tax is REDUCED in the ratio of net participation income to total net profit (it is not an exemption) where the company holds at least "10 Prozent am Grund- oder Stammkapital" OR at least "10 Prozent am Gewinn und an den Reserven" of another company, OR holds participation rights with a market value of at least one million francs.
• Net income, article 70: participation income less related financing costs and a flat contribution of "5 Prozent zur Deckung des Verwaltungsaufwandes" (or actual administrative costs if proved). Write-downs linked to the income reduce the relief.
• Gains, article 70(4): count only to the extent the sale price exceeds cost, AND only if the holding sold was at least 10 Prozent of capital or of profits and reserves AND was held for at least one year. After a part sale takes the holding below 10 Prozent, later sales qualify only if the holding had a market value of at least one million francs at the end of the tax year before the sale.
• Outbound: the withholding tax in the table is charged on dividends. For a Swiss-resident recipient it is a security tax that is credited or refunded; for others, treaty relief applies on claim. The treaty rates are not printed on the page read.

Singapore

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.iras.gov.sg/taxes/corporate-income-tax/basics-of-corporate-income-tax/corporate-income-tax-rate-rebates-and-tax-exemption-schemes
Corporate income tax rate	17%	"Your company is taxed at a flat rate of 17% of its chargeable income."

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.iras.gov.sg/media/docs/default-source/e-tax/tax-exemption-for-foreign-sourced-income285e5d43d6af4001b3ce35da1e9005b5.pdf
Foreign headline tax rate condition	15%	"“Foreign headline tax rate of at least 15%” condition"

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.iras.gov.sg/docs/default-source/e-tax/etaxguide_certainty-of-non-taxation-of-companies-gain-on-disposal-of-equity-investments.pdf?sfvrsn=ceb9a99_18
Section 13W minimum shareholding	20%	"the divesting company must still hold at least 20% of the ordinary shares and/or qualifying preference shares"

• Singapore dividends: under the one-tier system, dividends paid by a Singapore resident company are not taxable in the shareholder's hands ("as the tax paid by a company is final"), except dividends from co-operatives (IRAS dividends page).
• Foreign dividends received in Singapore by a resident company are exempt only if ALL three conditions hold: the income was subject to tax abroad; the foreign headline corporate rate is at least the 15% in the table when the income is received; AND the Comptroller is satisfied the exemption benefits the company. Foreign income is generally taxable when remitted to and received in Singapore.
• Gains, section 13W: for disposals from 1 January 2026, gains on ordinary shares and/or qualifying preference shares are not taxable if the divesting company held at least the 20% in the table for a continuous period of at least 24 months immediately before the disposal; from 2026 the 20% may be tested on a group basis. The scheme does not apply to non-listed shares in a company that trades immovable property, or whose principal activity is holding immovable property (Singapore or elsewhere, for disposals from 1 June 2022), or a company that "has undertaken property development activities (in Singapore or elsewhere)", unless it uses the property in its own trade and did no development in the past 60 months. A gain outside section 13W is not automatically taxable; it turns on the facts.

United Arab Emirates

Item	Value	Note (verbatim from the page)
Source	all figures below	https://tax.gov.ae/DataFolder/Files/Guides/CT/CT%20General%20Guide%20-%20EN%20-%2010%2009%202023.pdf
Rate on taxable income up to the threshold	0%	"0% (zero percent) on the portion of the Taxable Income not exceeding AED 375,000"
Threshold	AED 375,000	same
Rate above the threshold	9%	"9% (nine percent) on" the portion above

Item	Value	Note (verbatim from the page)
Source	all figures below	https://tax.gov.ae/Datafolder/Files/Guides/CT/CT%20-%20Exempt%20Income%20-%20Dividends%20and%20Participation%20Exemption%20-%2016%2010%202023.pdf
Minimum ownership	5%	"represents a 5% or greater ownership interest in a Participation"
Alternative acquisition cost	AED 4 million	"equal to or exceeds a specific threshold (AED 4 million)"
Subject-to-tax rate	9%	"equivalent foreign corporate tax at a rate of 9% or" more
Asset test	50%	"Not more than 50% of the direct and indirect assets of the Participation must consist of ownership interests which would not qualify"

Item	Value	Note (verbatim from the page)
Source	all figures below	https://tax.gov.ae/Datafolder/Files/Legislation/Corporate%20Tax/CT%20law%20final/Federal%20Decree-Law%20No.%2047%20of%202022%20-%20For%20publishing.pdf
Withholding tax, article 45	0%	"subject to Withholding Tax at the rate of 0% (zero percent) or any other rate as specified in a decision issued by the Cabinet"

• Participation exemption (article 23): ALL of these must hold: ownership of at least 5% OR acquisition cost of at least AED 4 million; held, or intended to be held, for an uninterrupted period of at least 12 months; the participation is subject to UAE corporate tax or an equivalent foreign tax at 9% or more (with exceptions in the guide); the interest entitles the holder to at least 5% of profits and liquidation proceeds; AND not more than 50% of the participation's direct and indirect assets are interests that would not qualify if held directly. Dividends from UAE resident companies are exempt without the participation tests (Corporate Tax Law, article 22).
• Gains on the disposal of a participating interest are exempt under article 23(5)(b) on the same participation conditions, for gains "derived after expiry of the 12-month holding period" (Exempt Income: Dividends and Participation Exemption, section 6.2.1).
• For setting up a UAE company, see ae-company-formation.

United Kingdom

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.gov.uk/government/publications/rates-and-allowances-corporation-tax/rates-and-allowances-corporation-tax
Main rate, financial year from 1 April 2026	25%	"Main rate (companies with profits over £250,000) 25% 25%"
Small profits rate	19%	"Small profits rate (companies with profits under £50,000) 19%"

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg53072
Substantial shareholding	10%	"when it holds at least 10% of the ordinary share capital of the investee company"

Item	Value	Note (verbatim from the page)
Source	all figures below	https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt11010
Pillar Two revenue threshold, 365-day period	EUR 750 million	"The revenue threshold is €750 million for an accounting period of 365 days."

• Dividends: a company that is not small is exempt on a distribution that falls into an exempt class in sections 931E to 931I of the Corporation Tax Act 2009, is not a deemed interest distribution, AND is not deductible for any foreign resident (INTM653010). The exempt classes and anti-avoidance rules are in INTM653000 to INTM654000 and are not reproduced here.
• A small company has its own exemption (INTM650000 lists "Exemption for small companies"), not covered here. For the rate bands, HMRC's Marginal Relief page says the limits are divided by the number of associated companies plus one, profits include "distributions from unrelated, unassociated companies", and "You cannot claim Marginal Relief if ... you’re a close investment holding company".
• Gains, substantial shareholdings exemption: the investing company must hold at least 10% of ordinary share capital AND be entitled to at least 10% of distributable profits and of assets on a winding up (CG53072), for a continuous period of at least 12 months; for disposals from 1 April 2017 that period may end up to five years before the disposal (CG53078). The investee must be a qualifying (trading) company throughout the qualifying period (CG53106). Since 1 April 2017 the investing company itself need not be trading.
• Pillar Two: the threshold in the table must be exceeded in two of the four periods immediately before the tested period.
• Outbound dividend withholding: not printed on an allowed page, on the pages read for this Guide.

Worked hypothetical

Hypothetical facts, not a real client. A family holding company receives a dividend of EUR 1,000,000 from an operating subsidiary and sells a stake at a gain of EUR 5,000,000. The subsidiary is a trading company resident in an EU state with a 15% or higher headline rate, the holding is thirty percent and has been held for three years, and no country's anti-abuse rule is triggered. Because the subsidiary is resident in the EU, not in Malta, and holds no Malta-resident interests, the article 12(1)(u) gains proviso above does not apply. All amounts are before any tax in the shareholder's home country.

Item	Value	Note
Source	all figures below	https://legislation.mt/eli/cap/123/eng/pdf
Hypothetical dividend	EUR 1,000,000	assumption
Hypothetical gain	EUR 5,000,000	assumption

Under those facts, each country's exemption above is met for both items, so the holding-level tax is nil in Malta, Cyprus, Ireland (section 831B elected, 626B met), Luxembourg, the Netherlands, Singapore (FSIE and section 13W met), the UAE and the UK. Switzerland reduces the federal tax instead of exempting: the reduction is in proportion to NET participation income (after financing costs and the 5 Prozent administrative charge), so some federal tax remains, and cantonal tax is outside this Guide. The difference between the countries is therefore in the cases where a condition fails, and in what the family pays when cash comes out.

Malta, condition fails. Assume instead the subsidiary is outside the EU and fails both anti-abuse limbs, no double taxation relief is claimed, and the dividend is paid on to a registered shareholder.

Step	Value	Note
Source	all figures below	https://legislation.mt/eli/cap/372/eng/pdf
Malta tax at thirty-five cents per euro on the dividend	EUR 350,000	hypothetical, article 56(6) Cap. 123
Refund to shareholder at five-sevenths	EUR 250,000	hypothetical, article 48(4A)(a)(i)
Malta tax left after refund	EUR 100,000	hypothetical

Malta refund on trading profit, for contrast. A Malta company with hypothetical trading profit of EUR 100,000 allocated to its Maltese taxed account, distributed to a registered shareholder.

Step	Value	Note
Source	all figures below	https://legislation.mt/eli/cap/372/eng/pdf
Hypothetical trading profit	EUR 100,000	assumption
Malta tax at thirty-five cents per euro	EUR 35,000	hypothetical
Refund at six-sevenths	EUR 30,000	hypothetical, article 48(4A)(a)
Malta tax left after refund	EUR 5,000	hypothetical

Netherlands, condition fails. Assume the holding is below 5% and never met the 1-year rule, so the dividend is taxable, and the company has no other income or deductions.

Step	Value	Note
Source	all figures below	https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/vennootschapsbelasting/tarieven_vennootschapsbelasting
First EUR 200,000 at 19.0%	EUR 38,000	hypothetical
Remaining EUR 800,000 at 25.8%	EUR 206,400	hypothetical
Dutch corporate tax on the dividend	EUR 244,400	hypothetical

Netherlands, cash out to a Dutch-resident family member. A hypothetical EUR 1,000,000 portfolio dividend paid to a Dutch-resident individual usually carries dividend tax at the rate in the Dutch table, credited against the individual's income tax.

Step	Value	Note
Source	all figures below	https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/zakelijk/winst/dividendbelasting/als_u_dividend_uitkeert/als_u_dividend_uitkeert
Dividend tax withheld at 15%	EUR 150,000	hypothetical

Cyprus, condition fails. Assume the subsidiary is a non-resident company more than 50% in investment-income activities and taxed abroad at less than 50% of the Cyprus burden.

Step	Value	Note
Source	all figures below	https://www.gov.cy/media/sites/167/2026/03/EEA-%CE%A6%CE%9A%CE%9A-%CE%9C%CE%95%CE%A4%CE%91%CE%A1%CE%A1%CE%A5%CE%98%CE%9C%CE%99%CE%A3%CE%97-06032026.pdf
SDC at 5% on the dividend	EUR 50,000	hypothetical; corporate tax exemption still applies

Not computed: Ireland, Luxembourg, Switzerland, Singapore, the UAE and the UK fail cases. Each depends on facts this hypothetical does not fix (trading or non-trading rate in Ireland, commune in Luxembourg, canton in Switzerland, whether a gain is capital in Singapore, the AED threshold in the UAE, the GBP bands and marginal relief in the UK).

How to choose

• If the family needs cash paid out regularly to individuals, compare the outbound row first: Singapore one-tier dividends and the UAE rate in the table cost nothing at the holding level on the way out; Malta works through refunds and deducts fifteen per cent on untaxed-account dividends paid to Malta-resident individuals; Ireland, Luxembourg, the Netherlands and Switzerland withhold at the rates in their tables unless an exemption applies; Cyprus charges SDC only on resident individuals and on some non-resident companies.
• If the holding is small or recent, the thresholds decide: Singapore section 13W needs at least 20% for 24 months; Luxembourg needs 10% or a large acquisition price for 12 months; the UK needs 10% for 12 months and a trading investee; Ireland, the Netherlands, Malta and the UAE start at 5%; Cyprus prints no minimum on the Tax Department page.
• If the subsidiaries are in low-tax or non-EU countries, the subject-to-tax tests decide: Malta's anti-abuse limbs, Singapore's 15% headline test, the UAE's 9% test, Ireland's relevant-territory test, the Netherlands' portfolio participation test and Cyprus's passive-and-low-tax SDC rule.
• If a subsidiary holds property, check the property carve-outs: Ireland 626B (Irish land), Singapore section 13W (property-trading or property-holding investees), Cyprus capital gains tax on property-rich shares.
• Then check the family member's own country (CFC) and where the company is really managed (residence and substance) before deciding. See cfc-and-substance-rules-compared and mt-company-residence-and-substance.

Ask the client first

• Where is each family shareholder tax resident and domiciled, and where will they be in five years?
• Where are the operating subsidiaries resident, what headline and actual tax do they pay, and do they trade or mainly hold investments or property?
• What percentage of each subsidiary will the holding own, at what acquisition cost, and since what date?
• Does the family need regular cash dividends, or will profits stay in the holding for reinvestment or a later sale?
• Where will the board meet and who will run the holding day to day?
• Does the group's consolidated revenue come anywhere near the Pillar Two threshold?

When to refuse or refer

• Refer to a licensed adviser in the chosen country before relying on any exemption: every one has conditions, anti-avoidance rules and filings this Guide summarises but does not reproduce in full.
• Refer if any subsidiary is in a jurisdiction on the EU list of non-cooperative jurisdictions, or in a no-tax or low-tax country: several tests here fail in that case.
• Refer for Swiss cantonal tax, Luxembourg municipal tax outside Luxembourg City, Irish close company surcharges and UK exempt-class detail, which this Guide does not compute.
• Refer the shareholder's home-country position (CFC, exit tax, treaty residence) to an adviser in that country.
• Refuse to treat the comparison table as a recommendation for a specific family without the facts in "Ask the client first".
• Refer Malta-specific questions (refund mechanics, the elective final tax, residence and substance) to mt-holding-company-participation-exemption and mt-company-residence-and-substance; Malta also has mt-capital-gains for sales of shares.

Sources

• Malta: Income Tax Act, Cap. 123; Income Tax Management Act, Cap. 372; L.N. 188 of 2025
• Cyprus: Income tax reform presentation 2026; SDC and CGT reform presentation; Corporate tax page; Withholding on payments to non-residents
• Ireland: Basis of charge; Tax relief charts; Participation exemption for foreign distributions; TDM Part 20-01-14; DWT exemptions for non-residents; Close companies
• Luxembourg: IRC rates; Overall tax burden; Parent-subsidiary regime; LIR coordinated text at 1 January 2026
• Netherlands: Corporate tax rates; Participations; Dividend tax when paying dividends; Participation dividend to a shareholder abroad
• Switzerland: DBG, status 1 January 2026; ESTV withholding tax
• Singapore: Corporate income tax rate; FSIE e-Tax Guide; Section 13W e-Tax Guide; Dividends
• UAE: General Corporate Tax Guide; Exempt Income: Dividends and Participation Exemption; Federal Decree-Law No. 47 of 2022
• United Kingdom: Corporation tax rates; INTM653010; INTM650000; Marginal Relief for Corporation Tax; CG53072; CG53078; CG53106; MTT11010