UK companies pay tax on dividends received from overseas subsidiaries at 33%; any taxes already paid by the subsidiary in its domestic market can be offset against this charge. So dividends from Germany, where domestic taxes can be as high as 60%, typically attract no UK tax, while additional taxes are payable on dividends from Switzerland, where domestic taxes are lower than in the UK, Under UK law, overpayment in one foreign country cannot be offset against underpayment in another. The solution is the so-called Dutch mixer - a holding company in the Netherlands - where such an offset is allowed and the profits from oveseas subsidiaries can be 'mixed'. Any dividend required by the parent is paid out by the Dutch company after the offsets have been utilised. This encourages the setting up of corporate HQs in low-tax Holland.
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