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

Transfer Pricing

India’s record APAs a win for government efficiency: experts

The promise of nine years’ tax certainty and a ‘rational and pragmatic’ government process makes APAs a no-brainer, Indian tax advisers tell ITR

Tom Baker, April 24 2025

Transfer Pricing

Fixing Italy’s approach to taxing digital business

Despite garnering significant revenues from multinationals, Italy’s digital services tax presents pressing double taxation issues, say Stefano Simontacchi and Francesco Saverio Scandone of BonelliErede

Stefano Simontacchi , April 23 2025

Direct Tax

Copy of What Corporates Want 2025 (1).png

Asian clients unimpressed with firms’ team depth, exclusive data reveals

ITR’s research shows that in-house tax counsel in Asia also feel underserved by their advisers’ international networks

Tom Baker, April 22 2025

Direct Tax

World Tax and ITR Awards: how to write a winning submission

World Tax global head of research Jon Moore tells ITR how his team spots standout submissions, and gives early statistical insights into this year’s entries

Tom Baker, April 21 2025

Direct Tax

This is the Australian Parliament House in Canberra. Which was t

Tax advisory regulation would be slashed under Aussie conservative government

Australia’s conservative opposition will repeal controversial tax agent reporting rules if elected in the country’s May general election

Tom Ravlic, April 18 2025

Direct Tax

This week in tax: Gary Shapley tipped to become acting IRS commissioner

Shapley would be the fourth person to hold the job this year; in other news, UK tax advisory firm MHA raised fewer funds than expected from its London IPO

Tom Baker, April 17 2025

Transfer Pricing

‘General pause’ on pillar one in many countries: BDO tax leader

The US needs to be involved in pillar one for there to be more international acceptance of the project, Michael Masciangelo says

Sam Sholli, April 17 2025

Direct Tax

EY’s regulatory troubles continue as FRC launches Post Office probe

The UK regulator is investigating EY’s auditing of the national postal service as it relates to the high-profile Horizon scandal, which saw hundreds wrongfully convicted

Tom Baker, April 16 2025

Direct Tax

EU flags waving in front of European Parliament building in Brus

Council of the EU adopts DAC9 pillar two simplification directive

The directive will extend cooperation and information exchange around pillar two, according to the Council of the EU

Sam Sholli, April 15 2025

Direct Tax

EY fined £5.25m by UK watchdog over auditing failures

Audit engagement partner Christopher Voogd has also been hit with a £32,500 charge over the firm’s work with Stirling Water Seafield Finance

Sam Sholli, April 14 2025