EU holding company structure in treaty shopping cases

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EU holding company structure in treaty shopping cases

August 23 2017
treaty

The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.

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Topics

PolandPortugalItalyTransfer PricingDirect TaxCroatiaTax DisputesCompliance ManagementSloveniaLatviaFranceSlovak RepublicLithuaniaLuxembourgDenmarkRomaniaCzech RepublicFinlandEstoniaBelgiumAustriaSpainGreeceGermanyMaltaSwedenFeatureHungaryBulgariaIrelandNetherlandsUnited KingdomITR MagazineSeptember 2017
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