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By Vincent REMY, Partner, Private Debt Leader, EY Luxembourg
The recent proposal for a new Directive(1) (referred to as the Anti-Tax Avoidance 3 or “ATAD 3” as well as UNSHELL Directive – hereafter the draft Directive) marks the next step of the Commission’s vision to provide a fair and sustainable European business tax system and to support the economic recovery from the pandemic and adequate public revenues for Member States. So-called “shell” entities are targeted i.e., undertakings with no or minimal economic activity, used as instruments of tax evasion or tax avoidance.
If an undertaking qualifies as a shell for tax purposes, access to double tax treaties or EU Directives will be disallowed. Transparency is further increased through an...
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