The Parent-Subsidiary Directive’s new anti-abuse clause has been adopted to curtail tax avoidance and aggressive tax planning by corporate groups. Member states have until 31 December 2015 to implement the new provision. The impact of the new anti-abuse provision will be felt in varying degrees across member states. The UK, with its no-WHT policy on outbound dividends and stricter anti-abuse rules on inbound dividends, will be little affected by this new EU provision.
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