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

Indirect Tax

Brazil’s tax reform: how the IBS impacts municipalities

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes

Wesley Fragas, March 25 2026

Indirect Tax

‘Welcome clarification’: experts dissect CJEU loyalty programme VAT ruling

While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions

Sam Sholli, March 25 2026

Direct Tax

Aerial view of Christ and Botafogo Bay from high angle.

Brazilian MNEs struggling to align pillar two with domestic tax incentives

While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard

Sam Sholli, March 24 2026

Direct Tax

Guinevere Moore on balancing tax litigation with childcare and ‘paying it forward’

Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series

March 24 2026

Direct Tax

Clients considering US relocation following pillar two carve-out deal: Baker McKenzie

But partners at the firm admit that jumping ship to the US would not be as easy as some believe

Tom Baker, March 23 2026

Direct Tax

A taxing week: AI is reshaping capital flows and toppling the old tax order

Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created

Teresa Owusu-Adjei, March 20 2026

Direct Tax

This week in tax: KPMG announces Gary Wingrove as new global chairman and CEO

Wingrove will succeed Bill Thomas, who has served in the role since 2017; in other news, Andersen unveiled a sharp increase in revenues for 2025

Sam Sholli, March 20 2026

Transfer Pricing

‘Clear limitations’: Italian advisers differ on intra-group financing TP ruling

Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases

Sam Sholli, March 19 2026

Direct Tax

Back office to backbone: tax risks of evolving global capability centres

As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management

Mehul Jain, March 19 2026

Direct Tax

‘Kept the family together’: EU tax chief praises US/OECD pillar two deal

While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’

Sam Sholli, March 18 2026