境外控股公司之運用──以資產規劃為中心

The Adoption of Offshore Holding Company－Focusing on Estate Planning

境外控股公司之運用方式多元，長久以來普遍運用於資產規劃中。近年來，在全球反資恐、反洗錢與稅務資訊透明化之趨勢下，境外控股公司之運用大幅受限，特別是節稅功能不若以往，然境外控股公司仍具有相對隱密、高度彈性等優勢，因此仍為資產規劃、家族傳承之有力工具。是本文擬以境外控股公司為主題，除介紹境外控股公司之功能與運用方式外，並以實際案例為佐，分析境外控股公司在資產規劃架構中之角色，並說明潛在風險與相關建議。

Offshore holding company has long been adopted in a wide variety of arrangements including estate planning. However, the advantages of the adoption of offshore holding company have been significantly decreased in the recent years due to the global trends of countering the financing of terrorism, anti-money laundering and enhancing tax information transparency, which substantially hinders the tax mitigation planning. Nevertheless, the characteristics of confidentiality and flexibility that offshore holding company contains still make it a practical and valuable tool in the field of estate planning and family inheritance. This article focuses on the functions of offshore holding company in estate planning. The author tries to analyze the role of offshore holding company in estate planning frameworks with a pragmatic approach. By conducting case study, this article will also expound the potential risks of the adoption of offshore holding company in estate planning along with relevant suggestions.