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  • ARTICLE - EU

    “She sells corporate shells” – New EU Directive on misuse of shell entities

    The EU Commission has published a proposal for a directive which will potentially impose new rules to prevent the misuse of shell entities for tax purposes.

    15 Feb

    On 22 December 2021, the European Union Commission published its new proposal. This proposal was for a new directive to “prevent the misuse of shell companies for tax purposes” (“The Proposal“).

    Its purpose will be to discourage the use and creation of shell companies within the European Union (EU).

    This will be in addition to the existing suite of tax avoidance rules. Clearly, the fact that the Proposal is required suggests that the EU Commission feels the existing rules are inadequate to prevent such shell entities.

    The Proposal would require information reporting to enable the respective competent authority to assess whether any new entity has a real and substantial presence, and economic activity, in the relevant jurisdiction.

    Benefits granted under EU law (so-called “treaty freedoms”) will be denied where there is no substance or economic activity.

    Further, the relevant entity will also be denied the issuance of a tax residency certificate.

    Its purpose will be to discourage the use and creation of shell companies within the European Union (EU).

    When will this all be introduced?

    It is anticipated that the new Directive should be adopted in early 2022 by the Council and implemented by member states, at the latest, by 30 June 2023.

    The provisions should subsequently be effective in all member states from 1 January 2024.

     

    What are we looking at?

    The key elements of the new proposals are as follows:

    • All entities (described as “undertakings”) will be in the scope of the new Directive: The Directive will apply to all entities that are resident for tax purposes in an EU member state. Any entity of any legal form that is engaged in economic activity is in the scope. There is no de minimis applied.
    • Gateway conditions: The Directive will introduce a set of conditions that enable the taxpayer and tax authorities to determine whether the relevant entity is considered a ‘risk case’ with a reporting obligation. The gateway consists of three conditions, that must all be satisfied. Where the entity does not satisfy this trio of conditions then it will be considered a ‘low-risk’ undertaking.
    • “Risk cases”: Reporting requirements will only apply to undertakings that are deemed to be so-called “risk cases”. These will be entities “that present simultaneously a number of features usually identified in undertakings that lack substance
    • Substance requirements: Risk cases with reporting obligations are required to include information on ‘substance indicators’ on its tax return. ‘Substance indicators’ are, for example, the availability of premises for the exclusive use of the undertaking, bank accounts, tax residency of its directors, and (if applicable) its employees. The undertaking will be considered to be a shell company in case the at-risk undertaking does not meet all substance indicators (i.e., fails at least one of the substance indicators).
    • What are the implications for ‘shell’ companies: In such a case, the entity will be denied the benefits of treaty freedoms – albeit it is limited to the specific shell entity and not the wider group.  Further, a certificate of tax residency will be unavailable to the shell company.

    Conclusion

    One would envisage that the Proposal will deter the creation of shell companies within the EU.

    These rules, along with other recent changes including the adoption of new OECD principles (including the global minimum tax rate) are likely to bring in additional complexity and a subsequent increase in compliance costs for international groups.

    If you have any queries about this article, or the matters discussed more generally, then please do not hesitate to get in touch.

    The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.

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    MR BLAKEFIELD. REGAL CAPITAL. FLORIDA.

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    MR BLAKEFIELD. REGAL CAPITAL. FLORIDA.

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