Background
- Mr. A is investing in European company, such as a French company (F Ltd);
- F Ltd performs well and will remit different type of payment to Mr A every year - such as dividend, interest and royalty etc. ;
- Mr. A forms a Hong Kong company (H Ltd) as 100% shareholder;
- H Ltd is 100% shareholder of a Luxembourg company (L Ltd);
- L Ltd is 100% shareholder of French company - the F Ltd;
- Payment from F Ltd reaches Mr. A via L Ltd and H Ltd.
- H Ltd and L Ltd is regarded as "Twin-Company" - there is double tax agreement between HK and Luxembourg;
- Luxembourg company also enjoys local tax benefit in Europe;
Withholding tax payable
by French companyIf no Twin-Company structure If used Twin-Company structure Dividend 25% 0% Interest 16% 0% Royalty 33% 0% - The income received by L Ltd and H Ltd is tax free - according to their respective tax rules.


