Investing in India or the United States of America through the Netherlands.

Alert, Aug. 28, 2014

The Netherlands is an attractive and advantageous location for an (intermediate) holding, finance and licensing company to set up a strategic company structurefor investments in the Republic of India (India) or the United States of America(United States). Primary benefits of a Dutch structure are the availability of theso-called Dutch participation exemption (no Dutch tax on qualifying dividendsand capital gains), the absence of an interest and royalty withholding tax onongoing interest and royalties, the favourable advance tax ruling system,the broad treaty network and the excellent and stable business climate.

This Tax Alert provides a brief overview of the advantages of structuring
investments in and from both India and the United States via a holding company
in the Netherlands.