The end of the "Unshell" directive (ATAD 3) | ATOZ Tax Advisers Luxembourg
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The end of the "Unshell" directive (ATAD 3) | ATOZ Tax Advisers Luxembourg
The end of the "Unshell" directive (ATAD 3) On 22 December 2021, the European Commission released a proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes, also called the Unshell Directive. Since its release, the draft directive has caused significant legal uncertainty due to its imprecise concepts and ambiguous substance indicators. Following several years of discussions between the EU Com…
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