12 February 2016 EU Anti-Tax Avoidance Directive has implications for banking, insurance and asset management sectors The European Commission released an anti-tax avoidance package on January 28, comprising of three separate documents: (i) a proposed European Union (EU) Anti-Tax Avoidance Directive (the ATA Directive), (ii) a proposed directive implementing the automatic exchange of country-by-country reports (the CbCR Directive), and (iii) a communication proposing a framework for a new EU external strategy for effective taxation. What is clear is that the future implementation of all or parts of the ATA Directive in its current form, or as amended, will have a significant impact on the taxation of cross-border financial services businesses and could represent a step change in European corporate taxation. A broad range of structures involving reverse hybrids, EU holding and financing companies and branches, among others, might be affected by the proposals, but the precise effect will depend on the exact legal structure and jurisdictional footprint of a business. Document ID: 2016-0311 |
