New article
On 22 December 2021, the European Commission published a proposal for a Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. This is the second action point of the European Commission’s new tax concept, Business in Europe: Framework for Income Taxation (BEFIT – more details: here). […]
New securities transfer tax risks in M&A transactions
On 22 December 2021, the European Commission published a proposal for a Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. This is the second action point of the European Commission’s new tax concept, Business in Europe: Framework for Income Taxation (BEFIT – more details: here). […]
A proposal for a new EU Directive to combat “shell entities” for tax purposes
While the abolition of the securities transfer tax has been discussed on various occasions over the last couple of years, aiming at a tax relief, two court decisions in 2021 led the practice in the opposite direction. After the Federal Supreme Court seemingly expanded the concept of intermediation with a new interpretation earlier this year, […]