Holding structures for
international investors.

A German holding GmbH is often the simplest answer for foreign investors to a complicated question: How do I enter the EU market with a legally secure, bankable, and substance-compliant structure?

The answer depends on the country of origin. Double taxation agreements (DTA), withholding tax rates, anti-abuse clauses, and substance requirements vary significantly. Below are the most important constellations as we see them in practice.

Saudi Arabia & GCC

With Vision 2030, the Saudi capital market has internationalized. The DTA between Germany and Saudi Arabia (since 2008) provides for reduced withholding tax rates on dividends (5%) and royalties. A German holding offers Saudi investors three structural advantages:

• Entry into the EU internal market through a single legal entity
• Bankability significantly higher than with pure KSA structures
• Substance-compliant BEPS structure, recognized by Western financial partners

United Arab Emirates

Since the introduction of the 9% corporate tax in the UAE (2023), home taxation remains low. The German holding complements EU market access, substance, and DTA benefits. The DTA UAE–DE provides for a 5% withholding tax on dividends. Ideal for investors looking to couple GCC-wide activities with a European sales base.

USA

The DTA with comprehensive protection against double taxation includes a LOB clause (Limitation on Benefits) that must be examined. A German holding can actively manage GILTI/Subpart-F issues and cleanly separate EU operations from US operations. For § 8b KStG-compliant exit plans, German holdings are particularly attractive.

United Kingdom

Post-Brexit, the German holding is the most pragmatic way for British investors to operate in the EU internal market. DTA since 2010, 0% withholding tax on dividends with at least 10% participation. Sterling/Euro account structure without issues.

Switzerland

One of the most attractive countries for DTAs. The Parent-Subsidiary Directive applies: 0% withholding tax from 10% participation. The combination of Swiss private assets and a German operational holding is standard in the UHNW sector.

Singapore

The APAC hub Singapore and the German holding together form a global distribution network. Tax-optimal, with a high compliance reputation and banking capability on both sides. For tech and service investors with an Asia plan.

The most important prerequisites

• substance: At least one managing director residing in Germany, business premises, own decisions on site.
• BEPS compliance: No mailbox constructions. ATAD requires economic activity.
• Bank account: KYC processes at German banks are strict. A professional address and a clearly structured client profile are crucial.
• Tax declaration: Double corporate and trade tax declarations plus DTA application. Rarely correct without experienced advice.

Typical structuring process at TABAK

1. Strategy workshop (1 week): Investor situation, target market, investment volume, planned activities.
2. Structure proposal (1 week): Legal form, substance concept, DTA application, tax modeling.
3. Incorporation (3–5 weeks): Notary, commercial register, bank accounts, tax registration.
4. Operational commencement (ongoing): Accounting, reporting, tax returns, international coordination.