ATAD: what does it actually mean for financing?
On 21 June, the Economic and Financial Affairs Council (ECOFIN) reached a consensus on the “Anti-Tax Avoidance Directive” (ATAD). Some of the measures of this Directive directly affect groups’ existing financing set-ups. The main impact is the implementation of BEPS Action 4 via a Directive, which will impose a general interest deduction limitation. Member States
ECOFIN agrees on Commission’s proposal on Anti-Tax Avoidance Directive
On 20 June 2016, the Economic and Financial Affairs (ECOFIN) Council agreed on the Anti-Tax Avoidance Directive (ATAD) proposal of the European Commission, following approval of the Dutch presidency’s final proposal by the Belgian government and no further comments from other Member States. On 8 June 2016, the European Parliament (EP) approved 91 amendments to
Is your upper-tier structure BEPS-proof?
The OECD BEPS Action Plan and parallel developments impact each layer of a multinational structure, including the upper tier. Specifically, having insufficient relevant substance at upper tier level could cause your return on investment to decrease significantly (by up to 25% based on the current Belgian withholding tax rate). On top, we expect that the
