Structuring a holding company is one of the most challenging tasks for tax advisors and businesses, because there are so many factors to consider in terms of taxation, residence and optimisation. The simple fact that a holding regime exists in a given country will not make the whole structure work. Here are the key aspects to consider when choosing a holding jurisdiction:

Income tax. In favourable holding jurisdictions, income derived from qualifying participations (i.e. dividends and capital gains) will ideally be fully exempt from corporate income tax. In many holding countries, full tax exemption is possible under specific participation exemption rules established by local legislation.
Outbound distribution of dividends. Dividends paid by a holding company to its parent company may be exempt from withholding tax under certain conditions. The final withholding tax rate may vary, depending on the residence status of the beneficial owner.
Double taxation treaties and the EC Parent-Subsidiary Directive. Tax treaties are aimed at reducing withholding tax rates on inbound and outbound dividends. Therefore, the most appropriate holding jurisdiction depends on the respective locations of the parent company and the subsidiary.
Tax residence status. Achieving tax residence status can be crucial for utilising the benefits of a holding company. Obtaining a tax residence certificate can be challenging but may be possible under certain conditions, such as having a resident director, a local rented office, local employees and others. Other obligations, like annual financial accounts, statutory accounts and tax returns, must be complied with at all times.
Substance. Very often there are substance requirements, with some countries stipulating a certain amount of substance in the holding jurisdiction before tax benefits can be obtained (so-called anti-abuse legislation).

Adult literacy rate in Nigeria is 59.6%. Male literacy is 69.2%. Female literacy is 49.7%. Therefore, male literacy and female literacy differ by 19.5%. Government expenditure on education is 0.8% of GDP. The education index of Nigeria is 0.425 - formal education levels are low and are mostly limited to primary and secondary school levels at best; higher education is possible, but not very widespread. People in Nigeria speak the English language.

English language
In Nigeria, around 0% of the population or 82,941,000 people speak English. 82,941,000 of Nigeria's population use English as either foreign or second language.

Today banking has the biggest share of the Luxembourg economy estimating by net worth and turnover. Back in year 2017 according to the data of the Global Financial Centres Index, Luxembourg was ranked as having the 18th most competitive financial center in the world, in the same time getting the third place of competition level amongst banks in European Union. Luxembourg has a narrow specialization in the trans-border finance administration industry. Due to the fact that Luxembourg's internal market is quite small, the country's financial centre is mostly internationally-oriented.

Today there are in total 144 banks on the territory of Luxembourg. Over 120 of them are actually branches and subsidiaries of international banks. Luxembourg's financial sector is currently one of the biggest contributors to the internal economy. The overall net worth of assets of Luxembourg banks are roughly estimated at nearly €760 billion. Luxembourg is also second largest global investment center following after the U.S.A.

Below you can find an overview of the top 6 biggest commercial banks in Luxembourg.

Deutsche Bank Luxembourg S.A.
Total volume of assets in year 2015: ~ €80,023,000,000

Annual total profit in year 2015: ~ €289,000,000

One of the biggest German banks - Deutsche Bank has successfully established a subsidiary bank on the territory of Luxembourg back in year 1970. Back in the days it was one of the first foreign subsidiary banks in the post-World War II period. Deutsche Bank Luxembourg was one of the original financial institutions which were incorporated in the state. Today Deutsche Bank Luxembourg S.A. provides wealth management services to wealthy private individuals and clients, issues international loans as well as provides agency services, corporate and investment related banking services, and retail investment services.

CACEIS Bank Luxembourg
Total volume of assets in year 2015: ~ €46,082,000,000

Annual total profit in year 2015: ~ €84,000,000

CACEIS originates from France. It specializes in fund management. CACEIS is a part of Credit Agricole Group - a French banking cooperative comprised of 39 smaller local banks. The bank was established in year 2003 and today one of the biggest financial institutions in the country. CACEIS provides wide range of services, including different kinds of deposits and custody related services, wealth management, transfer agency, as well as institutional and corporate banking services.

Banque et Caisse d'Epargne de l'Etat (BCEE)
Total volume of assets in year 2015: ~ €42,797,000,000

Annual total profit in year 2015: ~ €230,000,000

The Banque et Caisse d'Épargne de l'État (also known as BCEE) currently is the biggest domestic financial institution in Luxembourg. Better known as Spuerkeess in local language, it was established in year 1856 and since then is fully owned by the state of Luxembourg. The bank provides wide range of commercial and corporate banking services, including fund management, project investment, and narrow specialized private banking. Bank's long term credit rating according to Moody's is Aa2, which is a high grade.

Société Générale Bank & Trust
Total volume of assets in year 2015: ~ €36,399,000,000

Annual total profit in year 2015: ~ €406,000,000

Societe Generale Bank & Trust is one of the oldest international financial institutions based in Luxembourg. It was originally established as a branch bank of Société Générale Alsacienne de Banque (also known as OGENAL). In the past well known as Luxbanque Société Luxembourgeoise de Banque S.A., the bank had changed its name to Société Générale Bank & Trust S.A. back in year 1995. Societe Generale Bank & Trust currently provides a great variety of banking services and products, including wealth management, securities trading and fund management, provision of corporate financing services both in Europe and globally.

BGL BNP Paribas
Total volume of assets in year 2015: ~ €32,969,000,000

Annual total profit in year 2015: ~ €152,000,000

Banque Générale du Luxembourg (also known as BGL) was incorporated back in year 1919 as a local bank. In year 2009, BGL became a part of the international BNP Paribas Group. Today Banque Générale du Luxembourg offers banking products mostly in retail banking, individual wealth management, as well as corporate and institutional investment banking and fund management. BGL BNP Paribas' long term credit rating according to Moody's is A1, which is upper medium grade.

UniCredit Luxembourg S.A.
Total volume of assets in year 2015: ~ €19,728,000,000

Annual total profit in year 2015: ~ €64,000,000

UniCredit Bank historically was one of the first international financial institutions to operate on the territory Luxembourg. The bank is a part of UniCredit Group, which was established by a merger of several banks from Italy, Germany, and Austria, in addition to acquisitions in Central and Eastern Europe. Currently UniCredit Group runs several branches and subsidiaries in almost 50 countries of the world. The bank provides wealth management and corporate banking services and had been granted a long-term credit rating of A3, upper medium grade, according to Moody's.

The Republic of Cyprus or simply Cyprus is an island country in the eastern Mediterranean Sea and the third largest and most populous island in the Mediterranean Sea. Cyprus is north of Egypt, south of Turkey, west of Lebanon and Syria, north-west of Israel and finally – south-east of Greece.

As Cyprus is a former British colony, around 80% of the population is relatively fluent in English. Similarly, the legal system is also developed on the basis of the common law practiced in England. Cyprus is a free market economy which offers various opportunities including efficient tax planning for international companies. With top-notch accounting and legal services and an excellent geographic location, Cyprus is a great place to do business. The country is considered a leader among tax planning jurisdictions, so incorporating a company in Cyprus is an ideal way to protect your business. During the past decade, Cyprus' role in international tax planning has grown dramatically. As an EU member state, Cyprus has earned a reputation as a legitimate and reliable jurisdiction with over 40 double taxation treaties and some of the lowest taxes in the EU.

Advantages of acquiring a Cyprus shelf company
Once you have decided that Cyprus is the right jurisdiction for your company, you can either incorporate a new company or purchase a ready-made company. Ready companies are legal entities that were formed some time ago and have been “sitting on the shelf” ever since for investors to buy and run that business. Based on this comparison, ready-made companies are also referred to as shelf companies. Buying a shelf company has several advantages.

The main goal of a shelf company is to provide the investor with a company with a clean history, as older companies are often perceived as more trustworthy, reputable and reliable than newly formed companies. Acquiring a shelf company is also faster compared to the process of forming a new company. This turns out to be a great advantage for many entrepreneurs who need to start trading as soon as possible.

Acquisition of a Cyprus shelf company
Buying a shelf company in Cyprus is usually a simple and quick process. Companies specializing in the sale of shelf companies offer full service. This means that along with the company itself, they can also provide a full set of corporate documents, company secretary, registered office, nominee shareholders and directors, company bank account with internet bank and debit cards, VAT number and even support for the first year of operation possibly.

Usually the process of a shelf company acquisition is completely organized by the service provider and it only takes 24 hours before you can start trading. The process of buying a ready-made company can differ between different service providers, but usually 4 steps are required to buy a ready-made company:

Step 1. You select a company from a list provided on your service provider's website;

Step 2. Your service provider will send you a bill that needs to be paid;

Step 3. Submit a signed Know Your Client form, a copy of your passport and a utility bill in your name;

Step 4. The service provider prepares your chosen company and all the required paperwork including: all the company incorporation documents, an open share transfer agreement in your name, a Deed of Trust prepared for you by the shareholders and nominee directors and some other informative ones Documents . All documents will be sent to your address on the same day. Since the company is already registered and has a VAT number, you can start trading the same day.

It is important that you carefully consider which service provider is best suited to your needs, as the packages of services offered differ, as do prices and reliability. It is up to you to conduct full due diligence so that you can trust your service provider. For example, while some service providers offer shelf companies with a bank account already open, others offer the option of opening one after the company has been acquired, which will usually take several days.