Case

Regional holding company for asset management in Asia

Client: A.K., Moscow 2024 year
18 daysimplementation period

1 Task

The client, a private investor with production assets in China and Vietnam, owned shares directly through an individual, which created a high tax burden on dividends and complicated the consolidation of asset management in the two countries. A holding structure was needed to consolidate ownership of shares under a single company, reduce the effective tax rate on dividends from China, and simplify the group's banking services.

2 Decision

  1. HK Private Limited Registration — opened a Hong Kong holding company with nominee director and shareholder services to maintain beneficiary confidentiality.
  2. Corporate Account Opening — prepared a package of documents and passed a compliance check with Standard Chartered Hong Kong.
  3. Application of DTT Benefits — obtained a Hong Kong tax residency certificate and applied the reduced rate under the Hong Kong-China Double Tax Treaty.
  4. Transfer of Shares — organized the legally correct transfer of shares in production assets in China and Vietnam to the balance sheet of the new holding company.

3 Result

The structure was deployed in 18 business days. The effective tax rate on dividends received from China was reduced from 10% to 5% thanks to the application of DTT incentives. The client received a single point of asset management across two jurisdictions and simplified group banking services.

Grigori Ginzburg
Responsible specialist
Head of International Department (Berlin)
  • Languages – German, Russian, Latvian, English
  • Development of international corporate structuresConsulting on the choice of jurisdictionsSupport for company registration in Europe and the United StatesCoordination of cross-border projects and interaction with foreign registrars
  • Education: The European Economic Academy in Berlin
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