Typical investment structures of Chinese investors making their investments in a German company ("GermanCo") or a Greek company ("GreekCo") either directly from China, or indirectly from Hong Kong through the Netherlands or Luxembourg, may be depicted as follows:
As reflected in the following table and addressed in further detail under the heading International tax aspects, investing through Hong Kong may – in particular under the 1987 double tax treaty between China and the Netherlands currently still in force – also be preferable given the reduced dividend withholding tax rates that apply under the double tax treaty between Hong Kong on the one hand, and the Netherlands and Luxembourg on the other hand (withholding taxes in respect of interest and royalties are not relevant here given the absence of such taxes in the Netherlands and Luxembourg; see below).
