There is pressure to limit the existence and recognition of holding companies only to the extent that underlying substance and function is housed within the relevant jurisdiction. International tax law developments of the recent past and of the foreseeable future provide broad legal rules based on the OECD/G20 and the EU’s efforts to crack down on companies with slim infrastructure in low-tax jurisdictions or in countries with tax benefits for pure holding companies (especially IP-holding companies). This must be seen together with withholding taxes, non-deductibility rules for payments made to companies in low-tax jurisdictions, and the principal purpose test as well as limitation on benefits clauses. This panel will provide an overview of how international groups are responding to these developments.