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By Pierre-Régis DUKMEDJIAN, Partner Simmons Simmons Luxembourg LLP
On 22 December 2021, the European Commission published a proposal for a directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU(1) (also known as ATAD 3 and referred to in this article as “the Draft Directive”).
According to the Explanatory Memorandum which accompanies it, the Draft Directive aims to identify certain schemes used for the purposes of tax avoidance or tax evasion. These schemes concern the setting up of undertakings within the European Union (“EU”) which are supposed to have an economic activity but do not carry out any actual...
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