Monthly : May 2014

ECOFIN fails to reach agreement on anti-hybrid measure to be implemented into the Parent-Subsidiary Directive – FTT first on shares and some derivatives

9 May 2014

1. Background On 25 November 2013, the European Commission has proposed to amend the EU Parent-Subsidiary Directive (‘PSD’) in order to tackle tax fraud/evasion and aggressive tax planning/base erosion and profit shifting (‘BEPS’) within the European Union. The proposal sought to insert (i) a specific anti-abuse rule for hybrid loan arrangements resulting in a double