Transfer of shares French subsidiary

You may remember our client from Hong Kong with its Dutch subsidiary. Client intends to transfer the shares in its French subsidiary to the Dutch company. At present we are analyzing the most tax efficient way to transfer the French shares. This could be done for instance by way of a sale of the shares, a contribution of the shares into the capital of the Dutch company, or even more sophisticated ways.

We will limit our analysis not only to the Dutch corporate income tax aspects of the transfer, but will take also into account (where relevant) the VAT and dividend tax aspects. On top of that our French member firm of TGS global is looking at the French tax aspects of the above. We expect to report to the client within a couple of days.