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§00Structure · Glossary

Foreign Parent Entity

A non-U.S. holding company that owns a U.S. operating subsidiary.

In full

A foreign parent entity — typically a Dutch BV, UAE Mainland LLC, Singapore Pte Ltd, or Irish DAC — owns a U.S. operating subsidiary. The relationship is governed by the arm's-length transfer pricing rules, and intercompany payments (royalties, services, interest) are subject to withholding rules tempered by the parent's home-jurisdiction treaty.

This definition is general information about how the term is used in U.S. cross-border tax. It is not advice, and how it applies depends on your own facts and on the treaty, if any, in force with your country.