
The European Commission (EC) has published a Directive (also referred to as ATAD 3) aimed at EU based shell entities that do not meet a minimum substance threshold. Rhiannon Kinghall Were, head of tax policy at international law firm Macfarlanes, argued in a briefing note on 31 December that "this reflects a renewed interest in tackling the use of such entities and tightens the screw on the use of holding companies in the EU". "The rules are designed to introduce a common minimum substa...
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