The proposals to be introduced by BEPS 2.0 and ATAD 3 represent the latest challenge to the use of holding companies in corporate structures, with BEPS 2.0 potentially giving rise to the re-introduction of withholding taxes where they had historically been falling away, and ATAD 3 bringing in prescriptive substance requirements. These latest developments in the story of holding company anti-abuse measures will require corporate groups to review their holding structures and make changes if those structures could be affected by current trends or the proposed new measures.
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The proposals to be introduced by BEPS 2.0 and ATAD 3 represent the latest challenge to the use of holding companies in corporate structures, with BEPS 2.0 potentially giving rise to the re-introduction of withholding taxes where they had historically been falling away, and ATAD 3 bringing in prescriptive substance requirements. These latest developments in the story of holding company anti-abuse measures will require corporate groups to review their holding structures and make changes if those structures could be affected by current trends or the proposed new measures.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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