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“If you make 10,000 regulations you destroy all respect for the law” – Winston Churchill, 1949
By Yacine DIALLO and Pierre-Philip LEROUX-MOGA, Charles Russell Speechlys – Luxembourg (Avocats)*
One year has passed since the European Commission published a draft directive setting-out rules to prevent the misuse of so-called “shell entities” and we are still waiting for the final version to be enacted. This topic has been thickly discussed by tax practitioners in order to evaluate its potential impact on EU inbound and outbound investments structuring. It was initially envisaged for these new provisions to be effective as from 1st January 2024. Despite limited amendments formulated by the Committee on Economic and Monetary Affairs(1)...
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