EC proposals to tackle cross-border tax hybrid schemes
Sjoerd Douma & Bob van der Made, PwC, set out the key proposals.
On 25 November the European Commission proposed amendments to the Parent-Subsidiary Directive 2011/96/EU (‘the PSD’) in the context of the fight against tax fraud and evasion and aggressive tax planning/BEPS in the EU. The proposal seeks to tackle hybrid financial mismatches within the scope of application of the PSD and to introduce a general anti-abuse rule (GAAR) to protect the functioning of the directive.
The proposal follows the political guidance agreed in 2009 within the EU’s code of conduct group on business taxation to avoid the distorting effects of mismatches resulting from differences in the tax treatment of hybrid loans between EU member states. The proposal allows this political guidance to be implemented in domestic tax law. If the EC’s proposal would be adopted by the EU member states article 4(1)(a) of the PSD...
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:
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 'customer.services@lexisnexis.co.uk' for further assistance.
Home >Articles > EC proposals to tackle cross-border tax hybrid schemes
EC proposals to tackle cross-border tax hybrid schemes
Sjoerd Douma & Bob van der Made, PwC, set out the key proposals.
On 25 November the European Commission proposed amendments to the Parent-Subsidiary Directive 2011/96/EU (‘the PSD’) in the context of the fight against tax fraud and evasion and aggressive tax planning/BEPS in the EU. The proposal seeks to tackle hybrid financial mismatches within the scope of application of the PSD and to introduce a general anti-abuse rule (GAAR) to protect the functioning of the directive.
The proposal follows the political guidance agreed in 2009 within the EU’s code of conduct group on business taxation to avoid the distorting effects of mismatches resulting from differences in the tax treatment of hybrid loans between EU member states. The proposal allows this political guidance to be implemented in domestic tax law. If the EC’s proposal would be adopted by the EU member states article 4(1)(a) of the PSD...
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:
