Glossary
Participation exemption
A rule that exempts dividends and capital gains a holding company receives from qualifying shareholdings from corporate tax, to avoid taxing the same profit twice.
Under a participation exemption, when a qualifying holding company receives dividends from — or sells its stake in — a subsidiary it owns, that income is exempt (or nearly exempt) from corporate tax. The conditions usually involve a minimum shareholding and holding period.
Why it matters
It is the core reason to route group ownership through jurisdictions like the Netherlands, Cyprus, Malta or Singapore: profits can flow up and gains can be realised without an extra layer of tax at the holding level.
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