Holding

Latvia, Cyprus, Bulgaria

Three EU companies for holding shares, ETFs, or participations, when the annual running cost stays in the low thousands of euros.

This is not tax advice. The rates come from the sources at the bottom, read in October 2026. The country where you live can tax the profit even while it stays in the company.

Three questions

Compound. While the profit stays in the company and goes back into securities, local tax is deferred or absent. That is the only compounding the structure adds.

Distribute. The day the money comes back to the person, a second tax can appear: tax on distribution, withholding, then tax in the country of residence.

Keep the fees down. Accounting, office, audit. The original slides aimed at a budget under €3,000 a year. The site’s cost bands, below, are wider, especially in Cyprus.

The scope is a listed portfolio, venture capital, shares in European companies. Not a local trading business.

What stays out

The Netherlands and Luxembourg have real holding regimes. The ranking gives them 10 on the holding axis, then an exit around 38% and substance that pushes the bill up. For a portfolio still being built, cost comes before the regime.

Ireland taxes trading income and passive income apart. A holding without local directors is a poor fit.

Malta has a participation exemption, and 9.5 on the holding axis. The 6/7ths refund, on that route, takes months. The site’s cost note says agents and substance sit outside a light structure’s budget. Detail is in the Malta / Cyprus comparison.

Greece exempts a participation of at least 10% held for 24 months, including outside the EU from tax year 2025. That frame is a subsidiary, not an ETF portfolio. The ranking has no company sheet for Greece.

Latvia

Since 2018, corporate tax does not hit retained profit. It hits the distribution. The Ministry of Finance describes the ordinary rate: 20% of the gross amount, or 20/80 of the net dividend. The person who receives that dividend pays no extra Latvian income tax.

From 1 January 2026, a company whose shareholders are only individuals may elect 15% (15/85 of the net) and withhold 6% income tax. The Ministry says the election covers the distributions of the period. On €4,800 of profit paid out in full, the 20/80 regime leaves €3,840. The 15% plus 6% option leaves about €3,835. The headline rate falls. The cash received stays in the same range.

The KPMG Tax Card 2026 describes two exemptions. Dividends that pass through the company are not taxed a second time if tax was paid, or withholding taken, on the first distribution, and the subsidiary is not in a low-tax jurisdiction. Gains on shares go into profit and are taxed only on distribution. They drop out of tax if the shares were held directly for at least 36 months, and the company sold is not more than 50% Latvian real estate.

The case is a portfolio left to grow. The payout to the person is still taxed.

Cost, site note (July 2026): SIA registration often €150 to €250, micro capital from €1 possible, year one often cited at €2,000 to €3,500 with an address and accounting. Annual band: $1,200 to $4,000.

Cyprus

Corporate tax is 15% from 1 January 2026. It was 12.5% through 31 December 2025. Slides that show 12.5% describe the previous year. Source: PwC, Tax Facts & Figures 2026.

A disposal of securities is fully exempt: shares, bonds, units, and the rights attached to them. Dividends received are exempt from corporate tax, unless they were deductible for the company that paid them.

Special Defence Contribution can still hit a foreign dividend when its exemption does not apply. PwC records an effective foreign tax below 7.5% as significantly lower from 2026. The contribution on that dividend is then 5%, against 17% before. Interest earned by a company is inside the 15% corporate tax from 2026. Cash that earns interest is no longer outside tax.

Cyprus generally withholds nothing on a dividend paid to a non-resident shareholder. PwC, withholding taxes describes a 17% withholding to a company in an EU-blacklist jurisdiction, and, from 2026, a withholding to a related company in a low-tax jurisdiction. The shareholder’s country of residence can still tax the dividend.

The share-for-share exchange into a Cyprus holding is on the setup page, with the graphic and the cited figures.

Cost, site note: professional formation often €1,200 to €2,600 plus registrar fees. Published annual cost around €2,000 to €6,000 for a standard Ltd, audit included. Site band: $2,500 to $6,500. Slides at €2,500 a year are the bottom of that range.

Bulgaria

Corporate tax is 10%. Deloitte, Bulgaria Highlights, January 2026 confirms the rate, and the switch to the euro on 1 January 2026. The lev peg is no longer the point.

Dividends received from an EU or EEA company are left out of taxable profit. Gains on shares listed on a Bulgarian, EU, or EEA regulated market, or on a third-country market treated as equivalent, are exempt. A sale of unlisted shares goes into the 10%.

PwC, withholding taxes, reviewed 2 August 2026: 5% on a dividend paid to an individual, 0% to an EU or EEA company. The slides’ “100% if listed in the EU/EEA” is that listed case, not a private-equity exit.

Cost, site note: registry around €100, capital of €1. Year one often €1,500 to €3,000 with accounting. Annual band: $1,000 to $3,000.

Side by side

In the ranking, Holding profile, Latvia is 12th, South Cyprus 13th, Bulgaria 19th, out of 43 company sheets. The holding axis is 8.5, 9.5, and 6. Bulgaria is on this page for the rate and the fees.

€30,000, a gain of €4,800

An illustration. €30,000 of capital, a 16% gain, €4,800. Two columns: the gain stays in the company, or it is paid in full to an individual. Tax in the country where that person lives is not in the table.

Latvia: 20/80 on the €4,800, which is €960, and no Latvian income tax. Cyprus: the €4,800 assumes a non-resident shareholder and none of the withholding cases above. Listed Bulgaria: 5% withholding on €4,800. Taxable Bulgaria: 10%, then 5% on the remainder.

The slides compared this with a French company at 25%, €1,200 of tax and €3,600 kept. That figure assumes a gain taxable at corporate tax, with no participation regime.

In practice

Banking. An account at a high-street bank, for a Bulgarian or Cypriot company without local residence, is often refused, or slow. The slides named Revolut Business, Qonto, Wise, Airwallex, Interactive Brokers, and Saxo. Whether a holding is accepted changes by institution, and from one month to the next. This page recommends no provider.

Beneficial owner. The register is mandatory. A mismatch between the register, the articles, and the bank file blocks the account. Passport, proof of address, source of funds, and tax number belong in the file before the bank.

Anti-abuse. Withholding relief between EU companies is not automatic. A structure with no recorded investment decision can be recharacterised. It needs a real address, accounts kept locally, and decisions that leave a trace.

Residence. CFC rules where you live can tax profit that was not distributed. Substance and CFC.

How to choose

• Does the profit need to stay for years, or leave on a sale of securities?
• Are the securities listed in the EU, or private?
• Does the annual budget fit the Bulgarian or Latvian band, or does it allow a Cyprus audit?
• Do banking, reputation, and the CFC rules of the country of life still work? The ranking scores them.

Ranking, Holding profile Cyprus sheet Bulgaria sheet

Setting it up

The slides counted six to twelve weeks, plus two weeks if the file or an apostille drags. That timing was not measured here.

1. Frame

   Aim, country, budget for formation and two years, provider.

2. File

   Passport, proof of address under three months, source of funds, tax number, organisation chart.

3. Company

   Articles, register, beneficial owner. VAT only if an activity triggers it.

4. Account and broker

   IBAN, capital paid in, a test transfer, a securities account in the company’s name.

5. Books

   Local accounting, then the first purchases of securities.

Sources

• Latvia, Ministry of Finance, corporate income tax and changes from 1 January 2026
• Latvia, KPMG Tax Card 2026: pass-through dividends, gains after 36 months
• Cyprus, PwC Tax Facts & Figures 2026 and withholding taxes
• Bulgaria, Deloitte Highlights, January 2026 and PwC, withholding taxes, 2 August 2026

The original slides left Malta off this list, showed 12.5% for Cyprus, and a lev pegged to the euro. This page keeps their outline: why a holding, who drops out, three countries, a table, an example, the practical risks, the criteria, the path. The rates are those of October 2026. The cost bands are the site’s sheets, July 2026.