Choosing a holding location in 2026 is no longer a primary tax optimisation question, but a strategic decision on Pillar Two compatibility, demonstrable economic substance and compliance reputation. Six leading jurisdictions in a comprehensive comparison — with concrete recommendations for different investor and transaction profiles.
The UAE has established an entirely new tax architecture with the introduction of a 9% corporate income tax (June 2023) and Pillar Two-compliant Qualified Domestic Minimum Top-up Tax. Dubai and the Abu Dhabi Global Market (ADGM) position themselves as bridge jurisdictions for transactions between Asia, Europe and Africa.
Read full article →Singapore combines political stability, a robust network of double tax treaties, sophisticated asset management regulation by the MAS and an attractive tax regime for fund structures. For investors with an APAC focus, Singapore is the undisputed first choice for structured financing platforms.
Read full article →Luxembourg is the undisputed market leader for cross-border fund vehicles (RAIF, SCSP, SIF) and securitisation transactions. Over €5.5 trillion in assets under management demonstrate regulatory maturity and institutional infrastructure. The article analyses relevant vehicle types, tax specifics and positioning under Pillar Two.
Read full article →The Netherlands remains a leading location for operative EU holdings despite tightening of the participation exemption and increased substance requirements. Established M&A back-office infrastructure, a broad DTA network and high-quality ATAD implementation keep the Netherlands in the first tier of European holding jurisdictions.
Read full article →Ireland's Knowledge Development Box (KDB) with a 6.25% effective tax rate on qualifying IP income, combined with a broad DTA network and legal certainty from the Revenue Commissioners, makes Ireland the preferred location for IP-intensive pharmaceutical and technology structures under Pillar Two's nexus approach.
Read full article →Switzerland offers internationally competitive effective corporate tax rates of 12–14% at cantonal level — combined with political stability, legal certainty and excellent infrastructure for group treasury centres and commodity trading structures. Geneva and Zug remain leading locations for international principal companies.
Read full article →