Investment Fund Analysis & Strategy

ATAD III PwC ATAD III Shareholder Company B Source C Dividend Dividend Treaty relief? Reduction? I No WiT due to PSD • . What is it? Proposal for a directive to prevent the misuse of shell entities for improper tax purposes. When? Member states should apply the measures by January 1, 2024 with a two year "look back" period. Scope? All undertakings, being considered tax resident (tax residency certificate in a Member State). When is an undertaking potentially considered to be a shell? To determine this, the "gateways" and substance should be tested for the entity in the case at hand. Consequences? If not enough substance, benefits of tax treaties and EU directives can be denied (+ reporting obligation). 27 27

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