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Corporate responsibility is becoming more and more important
In addition to that many jurisdictions are implementing CFC rules and anti tax heaven legislation. Both developments make the oil majors reconsider their tax structures.
A trend we see in this respect is that corporates are looking for possibilities to migrate tax heaven subsidiaries to acceptable jurisdictions from both a political and tax perspective. In this respect the tax consequences of moving companies to other jurisdictions is very important. In many cases exit taxes (or similar taxes) become due.
In this respect we see BVI companies being moved to the Netherlands. However, since the Netherlands do apply the incorporation doctrine it can not be direct migration form e.g. BVI to the Netherlands. Often Luxembourg is uses as steppingstone into Europe. Thereafter, the company can be merged into a newly incorporated Dutch B.V. Other hub-jurisdictions are considered in this respect as well, e.g. Malta.