Tax Journal

The CERHA HEMPEL Tax Journal provides an insight and in depth articles on current topics in corporate tax law, international tax law as well as tax controversy. Our team members are dually qualified as attorney-at-law as well as tax advisors and regularly advise clients in M&A transactions, reorganisations and tax structuring. We represent our clients in all aspects of tax controversy including tax audits, tax litigation and fiscal criminal law.

Authors

Dr. Benjamin Twardosz, LL.M.

Dr. Benjamin Twardosz, LL.M.

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Dr. Christoph Schimmer, MSc

Dr. Christoph Schimmer, MSc

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ATAD 3: Proposal by the EU Commission for a directive with new rules targeting the misuse of shell entities for tax purposes

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On 22 December 2021 the EU Commission published a proposal for a new anti-tax avoidance directive laying down rules to prevent the misuse of shell entities for tax purposes (the ATAD 3 Proposal). The proposed directive is a result of the so-called “Unshell Initiative” and was already announced on 18 May 2021 with the Communication on Business Taxation on the 21st century by the EU Commission.

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