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Business Owners and SMEs · Holding Structures

A well-structured holding company organizes your group and maximizes your tax margin.

A holding company isn’t just a trend—it’s the way to centralize ownership of your businesses, protect your assets, and efficiently reinvest profits. When well-designed, it qualifies you for the exemption under Article 21 of the Corporate Income Tax Law. When poorly designed, it invites a tax audit. We design yours based on a genuine business purpose.

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Exemption under Article 21 of the LIS
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The Challenge

A holding company with no economic rationale is a risk, not an advantage.

The exemption provision under Article 21 of the Corporate Income Tax Law (LIS) allows for 95% of dividends and capital gains from the sale of shares to be exempt when the shareholder has held at least 5% of the shares for more than one year. The benefit is enormous, but it comes with conditions: without substance or a valid economic reason, the tax authorities will challenge it.

The most costly mistake isn’t setting up the holding company too late, but setting it up the wrong way—as a mere vehicle for holding assets, without any business logic behind it. We design the structure so that it can withstand scrutiny, not just to look good on an organizational chart.

  • A holding company established without a valid economic purpose or real substance.
  • Percentage or holding period that violates Article 21 of the Income Tax Law.
  • Planned transfer of ownership interests without analyzing the exemption.
  • Generational transition addressed without the appropriate corporate structure.

How we can help you .

Design

Structural Design

We define which company is a subsidiary of which, with what percentages, and for what purpose. Form follows function—never the other way around.

Exemption

Access to Article 21 of the LIS

We verify ownership, timing, and substance to ensure that dividends and capital gains are 95% tax-exempt with legal certainty.

Succession

Succession and Generational Transition

We structured the holding company in accordance with the family protocol and the tax benefits for family-owned businesses to facilitate the succession plan.

Defense

Defense of the Economic Grounds

We document the business rationale behind the structure and defend it before the tax authorities if an audit is conducted.

How We Work

From the idea to the operational structure.

1
Group Assessment
We analyze your companies, investments, and financial and tax goals.
2
Design and Economic Rationale
We define the structure, its business logic, and the requirements of Article 21 of the LIS.
3
Construction and Armor
We set up the holding company, document its substance, and defend it against the tax authorities.
Book your first consultation

Why Us.

Tax professionals, not company formers

We do not sell off-the-shelf holding companies. We design structures based on real economic needs—the only ones that stand up to scrutiny.

Family Group Vision

We combine the holding company structure with generational succession, the family protocol, and the benefits of a family business. A single strategy.

Direct dealings

You'll work directly with the tax attorney who designs your structure, not with an intermediary. Service available in 4 languages.

Preguntas frecuentes

Your questions, answered.

The main one is the tax exemption provided for in Article 21 of the Corporate Income Tax Law (LIS): 95% of dividends and capital gains from the sale of shares are exempt if you have held at least 5% of the shares for more than one year. Added to this are the efficient reinvestment of profits among subsidiaries and the group’s potential tax consolidation.
No. A holding company makes sense when there are multiple companies, a growing group, a family business, or new investors. Setting one up without a sound business rationale adds no value and increases tax risk.
It is the business rationale that justifies the structure beyond tax savings: centralizing management, protecting assets, and facilitating investment or succession. Without it, the tax authorities may deny the tax benefits and require the transaction to be brought into compliance. It is the aspect we take the greatest care with.
It helps separate business assets from personal assets and isolate risks among subsidiaries, but it is not an absolute shield. We design it in conjunction with the rest of your estate planning so that the protection is real, not just for show.
Yes, that’s one of its main benefits. A well-structured holding company makes it easier to transfer control in an orderly manner and take advantage of the tax benefits available to family businesses in the areas of estates and gifts. We integrate this with the family protocol.
We are licensed attorneys: we document the financial rationale and the nature of the holding company from the outset, and if an audit or tax assessment occurs, we handle appeals and proceedings through to the end.

Your group deserves a well-thought-out structure , not a makeshift one.

A tax attorney will review your case and tell you whether a holding company makes sense for you and how to set one up safely. No obligation.

Study my structure 965 92 91 94
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