There is no single best place. The right home depends on where your subsidiaries are, where the owners live, and what each country taxes on the way in and on the way out. Compare the options on the same questions before you look at headline rates.
The questions that decide it
- Treaties. Does the country have tax treaties with the countries where your subsidiaries are, so dividends reach the holding company with less tax withheld?
- Dividends received. Are dividends from subsidiaries exempt, and on what conditions?
- Disposals. Is a gain on selling a subsidiary taxed?
- Dividends paid out. Does the country withhold tax when the holding company pays its shareholders?
- Substance. Can the company show real people, premises and decisions there? See What does substance actually mean for my company?
Where the owners live
This often matters more than the holding country itself. The owners' own country may tax dividends when they receive them. If they run the company from home, it may also treat the company as managed there. See Where is my company taxed if I run it from another country?
The UAE as an example
Under the UAE Corporate Tax Law, a UAE company can exclude dividends and disposal gains from a foreign subsidiary if it holds at least 5% for at least 12 months and the subsidiary is subject to tax at 9% or more, among other conditions. The law sets withholding tax on payments to non-residents at 0%.
Reputation and banking
Banks and counterparties will ask what the company does and who runs it. A jurisdiction with a good reputation and a company with a clear purpose make accounts easier to open and keep.
An example
Takeshi is Japanese, lives in Dubai and owns trading companies in two Asian countries. He compares a UAE and a Singapore holding company on the same list: treaties with both countries, tax on dividends and gains, and tax on payments to him. He will make the decisions himself from Dubai, so a UAE company is easier to support with real substance.
Quick questions
Is the lowest tax rate the best choice?
Not on its own. Withholding on the way in, tax in the owners' country and the cost of real substance can outweigh a lower headline rate.
Do I need a treaty with every country?
Not necessarily. Without one, though, dividends from a subsidiary may suffer that country's full withholding tax.
Sources: UAE Ministry of Finance: Federal Decree-Law No. 47 of 2022 on Corporate Tax, as amended.
General information as at October 2026, not advice. The examples are fictional and simplified, and the rules have conditions and exceptions not covered here. Take advice on your own circumstances, in each country involved, before acting.