The European Commission put forward a proposal in 2021 to tackle shell entities (known as ATAD 3). Despite widespread support for the concept, reaching agreement on the technical details of the Unshell Directive has proved...more
At its dawn, the ATAD 3 Proposal and its adverse tax consequences were considered by some as the demise of international investment and holding structures. Others pointed out the uncertainties surrounding key terms related to...more
Further to the request of the European Parliament for concerted EU action, the European Commission issued on 22 December 2021 a proposal for a Council Directive laying down rules to prevent the misuse of shell entities...more
A draft EU Council directive, known as ATAD 3, was issued by the European Commission as a proposal at the end of last year. The directive is aimed at countering the misuse of 'shell' entities and could impose adverse tax and...more
The European Commission (the "Commission") published a draft Directive on 22 December 2021, known as the anti-tax avoidance Directive III ("ATAD III"), aimed at preventing the use of shell companies for tax evasion and...more
While most of the European Anti-Hybrid Rules took effect on 1 January 2020, the last anti-hybrid provision – targeting the reverse hybrid mismatch – will enter into force in relevant EU jurisdictions (such as Luxembourg and...more
The German Federal Ministry of Finance has published a draft law for the implementation of the EU Anti-Tax Avoidance Directive (ATAD Implementation Act) on 10 December 2019. This draft includes inter alia a new section 1a...more
The Luxembourg government and the CSSF recently have taken a number of measures to combat money laundering and terrorist financing. In other developments: the current Luxembourg Brexit laws will be rendered inapplicable by...more
UK Case Law Developments - Valid notice crucial to tax indemnity claim - The Court of Appeal (CA) decision in Stobart Group Ltd v Stobart and another is a cautionary tale for any purchaser who, following the...more
We set out below a recap of some of the key European and international tax developments to note at the start of 2019. This alert provides a brief summary of the following...more
The French government presented the draft Finance Bill for 2019 on September 24, 2018. This draft is currently being discussed by the Parliament and is subject to potential changes....more
The Background: The European Commission has opened an in-depth investigation into a specific provision of the UK-controlled foreign company rules. The Issue: The Commission will investigate whether the UK's so-called Group...more
Poland recently amended its Corporate Income Tax law, effective Jan. 1, 2018. The Polish Government announced that the objectives of the amendment are to ensure that taxes paid by large companies, especially multinational...more
United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more