Market leading insight for tax experts
View online issue

‘Am I a shell?’ The new question facing EU entities

Speed read
A new EU draft directive (ATAD 3) could subject EU entities to additional reporting and, if ultimately ‘unshelled’, adverse tax consequences from as early as 1 January 2024. The rules are structured as a five-step process, with the first four steps filtering out entities that meet minimum substance requirements or do not result in a tax advantage, and step 5 imposing tax consequences on those that have not managed to escape under steps 1 to 4. If the directive is implemented, many businesses will need to take steps to bolster the substance of their EU holding companies to prevent additional reporting or adverse tax consequences.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.