Dutch
laws regarding the taxation of branches are extremely
attractive:
Profits
of a Foreign Branch: All profits, capital gains
and income of the foreign branch of a Dutch registered
parent company (whether those profits are repatriated
or not) are exempt from corporate income tax in Holland
(unless those profits have not been taxed in the foreign
jurisdiction in which the branch operates).
Losses of a Foreign Branch:
The losses of the foreign branch of a Dutch registered
company are tax deductible from the taxable profits
of the Dutch registered company. Thus where a project
is likely to initially run at a loss it may be advisable
for the Dutch company to set up a foreign branch since
the tax losses of the foreign branch are tax deductible
in Holland (whereas the tax losses of the foreign
subsidiary of a Dutch parent company are not).
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