Despite a tendency in business to a fragmentation of holding entities and a progressing use of more than one holding entity as a means to hold a variety of assets, as opposed to one single holding entity holding all the assets, tax rules typically look at each holding entity separately in order to test substance requirements allowing a holding to benefit from lower or no withholding taxes. The opposite rationale is being put forward by OECD BEPS Action 7: Effectively also about substance, the anti-fragmentation rules proposed are designed to “consolidate” all activities of connected enterprises that are part of a cohesive business operation in order to test the existence (substance) of a PE. Should such anti-fragmentation rationale take effect, it should be applied consistently in international tax law. Holding entities should be the main beneficiaries of a consistent approach, at least as long as they are controlled by the same persons.