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It is a bit of a public secret that both U2 and the Rolling Stones receive their royalties via the
Most countries levy tax on dividend, interest and royalties you receive from that country. This is referred to as ‘source tax’. The
This is one of the reasons why the
Dutch legislation contains specific provisions regarding companies focusing on conduit activities within concerns. If this is properly structured, only a small spread on the conduit activities is subject to company tax in the
Furthermore, you may offset any foreign source tax relating to the interest and/or royalty income against Dutch company tax. As a result, very little or no Dutch company tax is levied on conduit activities.
Eligibility for this favourable scheme is subject to strict conditions. For example, the company must have sufficient substance in the
If you are interested in such constructions, contact Bol International’s advisors to see what the most favourable construction would be in your case. They will be happy to advise you.
Also take legislation in your own country into account. This may have to be considered too.
A conduit company is considered to run a realistic business risk if the company has sufficient capital to cover any risks and the capital is actually affected if a risk occurs.
The requirements for interest conduit companies and royalty conduit companies differ in this respect. The minimum capital for an interest conduit company, for example, must amount to at least 1% of the loan outstanding, or € 2,000,000 if that is lower.
Of course, you may decide to hire an office in the
Another option is to involve a so-called trust office. A trust office is a company focusing on the management of companies, offering services in management and providing a statutory address.