EC amendments to Parent Subsidiary Directive address hybrid loans and introduce common GAAR

November 2013


On November 25, 2013, the European Commission proposed amendments (2011/96/EU) to the Parent Subsidiary Directive (PSD) to address tax fraud and evasion as well as aggressive tax planning and base erosion and profit shifting (BEPS) in the European Union. 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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