The (Un)intended Consequences of the Proposed Unshell Directive

Abstract

The European Commission recently released a proposed new directive aimed at preventing tax avoidance through the use of shells. Stephanie Kleefstra explains how the proposed directive ATAD 3 (the Unshell Directive) would work, and points out some of the consequences, intended and unintended, for taxpayers in the European Union, if and when ATAD 3 takes effect.