The study provides insights into the current tax treatment of group headquarter services in the Netherlands, Ireland, the United Kingdom and Switzerland. In case of Switzerland we focus on the Canton of Zug in general but also on the Canton of Nidwalden as far as the taxation of intellectual property is concerned. The study focuses on the taxation of holding companies, financing and treasury companies, research and development activities and the exploitation of intellectual property. To the extent that this is relevant, we also address special tax regimes that aim at other kinds of group services such as auxiliary services. The taxation of headquarter services is analysed by drawing on the methodology of Devereux & Griffith to determine effective marginal and effective average tax rates for hypothetical investment projects. To provide a benchmark for the results with regard to these specific headquarter functions, we at a priori calculate effective tax rates for a “standard“ manufacturing affiliate whose function is to produce manufacturing products. The results of the calculations are first analysed country by country pointing out the main tax drivers. In a second step, we focus on the different headquarter functions one by one and point out differences in the tax systems. Moreover, we explicitly point out the main advantages and disadvantages of the Netherlands as a location for HQ services.
Download of the results (as PDF)http://www.rechten.vu.nl/nl/Images/HQ%20Study_tcm22-276944.pdf