As previously announced, in the context of its ongoing fight against tax evasion and despite the as yet unknown impact of ATAD 1 and ATAD 2 on the EU market, on 22 December 2021 the European Commission published a proposed Directive targeting aggressive tax planning techniques linked to the use of shell companies; the proposed directive is being referred to as “Unshell” or ATAD 3 (the Proposed Directive).