EU holding company structure in treaty shopping cases

August 23 2017

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.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: HMRC’s GfC13 puts tax advisers in an unwinnable situation

The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations

Tom Baker, December 12 2025

Direct Tax

Taylor Wessing in merger talks with US firm Winston & Strawn

Taylor Wessing, whose most recent UK revenues were at £283.7m, would become part of a £1.23bn firm post combination

Tom Baker, December 12 2025

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

This week in tax: China adds to growing list of US pillar two carve-out dissenters

China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap

Sam Sholli, December 12 2025

Direct Tax