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By Yacine DIALLO – Partner Tax and Pierre-Philip LEROUX-MOGA – Associate Tax, Charles Russell Speechlys – Luxembourg (Avocats)
“If you make 10,000 regulations you destroy all respect for the law” – Winston Churchill, 1949
One year has passed since the European Commission published a draft directive setting-out rules to prevent the misuse of so-called “shell entities” and we are still waiting for the final version to be enacted. This topic has been thickly discussed by tax practitioners in order to evaluate its potential impact on EU inbound and outbound investments structuring. It was initially envisaged for these new provisions to be effective as from 1st January 2024.
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