Abstract
The aim of the EU proposal for ATAD3 is to prevent tax abuse using shell entities that lack relevant substance. One of the consequences of qualifying as a shell entity that ATAD3 proposes is that the shell entity shall not be entitled to tax benefits from the EU Parent-Subsidiary Directive. In this article, the author discusses whether this has implications for the application of the participation exemption in the Dutch Corporate Income Tax Act 1969.
| Translated title of the contribution | ATAD3: substance-ial consequences for the participation exemption? |
|---|---|
| Original language | Dutch |
| Journal | Nederland Fiscaal Wetenschappelijk |
| Volume | 2022 |
| Issue number | 17 |
| Publication status | Published - 23 May 2022 |
| Externally published | Yes |