A holding company over operating companies
The owners hold a group's operating companies through one holding company, so dividends, sales of subsidiaries and group financing pass through a single, well-documented layer.
Ownership chart
- Owner A owns 70% — Holding company
- Owner B owns 30% — Holding company
- Holding company owns 100% — Operating company
- Holding company owns 60% — Joint venture
- Partner's company owns 40% — Joint venture
A holding company gathers the group’s companies under one owner of record. Dividends flow up to it, a subsidiary can be sold by selling its shares, and financing can be raised once and lent down. For the owners it means one set of shares to hold, pledge, transfer or pass on, instead of one for each company.
Cyprus is a common seat for this layer: dividends received and gains on shares are generally exempt there, it pays no withholding tax on dividends to non-residents, and EU directives and about 65 treaties reduce tax where the money comes from. Since 2026 the arithmetic depends more on substance — real decisions taken in Cyprus — and on where the money goes next, because payments to associated companies in EU-listed or low-tax jurisdictions now carry defensive withholding.
Who is the beneficial owner
Owner A holds 70% of the holding company and controls it, so A is a beneficial owner of every company below it, the joint venture included (42% by multiplication). Owner B holds 30% of the holding company — a beneficial owner of it and of the wholly owned operating company — but only 18% of the joint venture and no control over the holding company, so B is not a beneficial owner of the joint venture unless B controls it in some other way. The partner's company has its own beneficial owners, who must be identified the same way.
| Person | Through shares | Through a role |
|---|---|---|
| Owner A | 42% | — |
| Owner B | 18% | — |
What each layer files and keeps
- 01
The owners
Identity and address, tax residence, source of wealth, and the shareholders' agreement between them.
- 02
The holding company
Registers of members and directors, the beneficial-ownership filing and its annual confirmation, audited accounts and annual return, the tax return, board minutes showing decisions taken where it is resident, and transfer-pricing files for any loans.
- 03
The operating companies
Their own local accounts, filings and beneficial-ownership entries — each naming the owners above the holding company — plus dividend resolutions and the agreements with the holding company.
What to watch
- Every layer's beneficial-ownership filing names the same people, worked through the chain; registers that disagree are the first thing a bank notices
- Dividends from subsidiaries are exempt at the holding company only within the participation and anti-abuse rules; what the subsidiary withholds depends on its own country and the treaty
- Loans between group companies need written agreements and an arm's-length rate
- The holding company needs real decisions where it is resident, not only a registered office
What the dossier keeps
- The group chart, with the evidence for every holding
- Each company's registers and beneficial-ownership filings, reconciled with one another
- The dividend, loan and service agreements between the companies
- The calendar of every company's filings in every jurisdiction
Jurisdictions in this structure
General information, not advice. Facts are stated as of the date on each page. Law, lists and rates change; the professional who acts for the entity confirms what applies to it. Chrysos performs no regulated act and gives no legal or tax advice.