Update: Member States agree to amend Parent-Subsidiary Directive
The European Union’s (EU) 28 Finance Ministers agreed, on June 20, 2014, to amend the EU’s Parent –Subsidiary Directive (Directive), addressing the effects of tax arbitrage resulting from EU Member States’ varying tax treatments of hybrid loans. The Member States have agreed that the Directive’s benefits should not result in ‘double non-taxation,’ that is, income going untaxed
EU Member States agree to amend the EU PSD to tackle hybrid loan arrangements
On 20 June 2014, the EU’s Council of Economic and Finance (ECOFIN) Ministers took place in Luxembourg. ECOFIN agreed amongst others on the amendments to the Parent-Subsidiary directive (PSD) and adopted conclusions on the report of the Code of Conduct Group on Business Taxation. Proposed amendments on the Parent – Subsidiary directive The ECOFIN agreed
European Parliament’s draft report to the revised Parent Subsidiary Directive
On 28 January 2014, the European Parliament provided its draft report and draft amendments to the European Commission’s proposal for revision of the Parent-Subsidiary Directive. 1. Background On 25 November 2013, the European Commission has proposed certain amendments to the EU Parent-Subsidiary Directive in order to significantly reduce tax fraud/evasion and aggressive tax planning/base erosion and profit
EC proposed amendment of the Parent-Subsidiary Directive
On 25 November 2013, the European Commission (hereafter: EC) proposed amendments to the Parent Subsidiary Directive (2011/96/EU; hereafter: PSD) in the context of the fight against tax fraud and evasion and aggressive tax planning/BEPS in the EU. The proposal seeks to tackle hybrid financial mismatches within the scope of application of the PSD and to introduce a general
