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.