On Thursday 30 September, ATOZ, in partnership with Legitech, will be hosting a webinar, presented by our Tax Partner and Head of Transfer Pricing, Oliver R. Hoor, entitled “The New EU Initiative on Fighting Shell Entities: Will this be a game changer for Luxembourg?”.
Description
On 20 May 2021, the EU Commission launched a new initiative on fighting the use of shell entities and arrangements for tax purposes. The initiative was triggered by the impression on the part of the Commission that legal entities with no or only minimal substance, performing no or very little economic activity, continue to pose a risk of being used for aggressive tax planning structures. The EU Commission organised a public consultation and invited interested parties to share their views, via a questionnaire, by 27 August 2021.
However, the tax authorities of EU Member States already have a comprehensive arsenal of anti-abuse rules that allow them to tackle any kind of abusive situation as well as reporting that should allow them to be aware of any residual abuse.
As such, the questions arise as to whether the new initiative of the EU Commission could elevate existing substance requirements to a higher level and if this might be a game changer for Luxembourg.
Agenda
- Introduction
- Substance in international taxation
- The new EU initiative against shell entities
- Existing anti-abuse legislation
- Limits of anti-abuse legislation in an EU context
- Excursus: Managing substance in extraordinary times
- Concluding remarks
Information and registration here.