The Withdrawal of the ATAD 3 Directive – An Analysis of Attempts to Define the Required Physical Substance of EU Holding Companies

This note examines the impact of the decision to abandon the Unshell Directive proposal (ATAD 3) and whether or not the concept of a shell entity in ATAD 3 ought to be amended in future works to more effectively address the issue of tax avoidance through the use of such entities.

Authors

Publication Details

Journal
European Taxation
Published
2026-02-18
DOI
https://doi.org/10.59403/2j4vqxf
Primary Topic
Taxation and Legal Issues
Type
article
Field-Weighted Citation Impact
0.00
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article

The Withdrawal of the ATAD 3 Directive – An Analysis of Attempts to Define the Required Physical Substance of EU Holding Companies

Jakub Jankowski
European Taxation
Taxation and Legal Issues
article

The Withdrawal of the ATAD 3 Directive – An Analysis of Attempts to Define the Required Physical Substance of EU Holding Companies

Jakub Jankowski
article en

Abstract

This note examines the impact of the decision to abandon the Unshell Directive proposal (ATAD 3) and whether or not the concept of a shell entity in ATAD 3 ought to be amended in future works to more effectively address the issue of tax avoidance through the use of such entities.

European TaxationVol. 66(2/3)
Peace, Justice and strong institutions
Openalex Percentile: Top 53%
Taxation and Legal Issues
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