EC amendments to Parent Subsidiary Directive address hybrid loans and introduce common GAAR
The proposal addresses hybrid financial mismatches under the PSD and introduces a general anti-abuse rule (GAAR) to protect the directive’s functioning.
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The international tax services network provides access to recent tax news and advice on holding company structure, cross border financing and treasury solutions, controlled foreign company planning, profit repatriation, loss utilization, inbound and outbound structuring, managing intellectual property, tax efficient supply chain and shared services related to European tax law.