Luxembourg holding company (SOPARFI) Luxembourg holding company is not a single company form, which

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In the second half of 2007 CIFA Magenta largest shareholder equity and the sale of shares CIFA decided to dissolve our current special purpose company has not issued specific legal norms, only a few departments have the relevant provisions vuokraovi of this regulation. (Hui Fa [2005] 76), "the State Administration of Foreign Exchange by Domestic Residents through vuokraovi Overseas Special Purpose Financing and Return Investment foreign exchange management issues related vuokraovi to notice": "Domestic vuokraovi corporate assets or the domestic resident legal or natural persons resident in its territory held interest in offshore equity financing (including convertible debt financing) for the purpose of direct foreign enterprises to establish or indirect control. "" On Foreign Investors to Merge Domestic Enterprises "(effective September vuokraovi 8, 2006 implementation) thirtieth nine special-purpose company will be defined as: "a special purpose company means the Chinese domestic company or natural person for the realization of the foreign company in its actual domestic company equities get listed abroad, directly or indirectly controlled."
Luxembourg holding company (SOPARFI) Luxembourg holding company is not a single company form, which generally takes the form of a public limited liability company (SA), a private limited vuokraovi liability company (SARL) with partner vuokraovi companies (SC) of. Luxembourg holding company Holding vuokraovi exemptions can be divided into a holding company in 1929 and in 1990 the two companies SOPARFI trading and holding. 1990 SOPARFI trading and holding company, enjoy the Luxembourg participation exemption regime, you can get a wide range of tax exemptions, including dividends, capital gains and liquidation, but still as usual trading profits subject to income tax. In addition, in 1990 SOPARFI trading and holding companies can enjoy double taxation treaty between Luxembourg and many other European countries signed. Luxembourg has the full implementation of the guidelines issued by the parent company of the European Union, interest and royalties guidelines and merger guidelines. According to the guidelines, while in 1990 10% participation rights SOPARFI trading and holding company vuokraovi capital of not less than subsidiaries, dividends, bonuses and royalties from its acquired subsidiaries are not required to pay taxes at. Therefore, the Italian company to pay a special dividend to shareholders, dividends and royalties are not subject to tax. When the Avoidance of Double Taxation and Prevention of Fiscal Evasion Agreement based on income and capital 2 November 2007 signed between Hong Kong and Luxembourg, Luxembourg company paying the dividends, profits or royalties to Hong Kong companies, may be exempted from or pay a lower rate of withholding tax, Meanwhile, Hong Kong-based source of tax law (ie territorial) principle, only the profit tax from the local business, and do not tax foreign income. In addition, Luxembourg and Hong Kong has no exchange controls, free-flowing capital and other advantages, have prompted United to take a holding company model.
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But property vuokraovi law is agreed by the parties expressly prohibited substance independent insurance: vuokraovi Article 172 Regulations shall October vuokraovi 1, 2007 implementation vuokraovi of the "People's Republic of China Property Law": "security interest shall be in accordance with this Law and other laws conclusion of the security provisions of the contract. guarantee contract is a contract from the principal contract. principal contract is invalid, void the guarantee contract, except as otherwise provided by law. "
In addition, the attitude of the judicial vuokraovi practice of independent guarantee is not clear. Supreme People's Court on December 31, 1999 to make the (1998) by the final word No. 184, "Hunan Machinery Import and Export Corporation, the Hainan International Leasing Company and Ningbo Dongfang investment company agent import contract case" final judgment, explicitly rejected independence to ensure that the domestic judicial practice apply. Hebei Provincial Higher People's Court on May 11, 2000 in (2000), No. 50 Ji through a final word, "Cangzhou City-made protein amino acids and construction vuokraovi company offices in the West Bank Cangzhou Department loan guarantee dispute appeal in China" verdict the independent guarantee that the agreement "consistent with the law, should be supported."
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