On 22 December 2021, the European Commission released a proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes, also called the Unshell Directive. Since its release, the draft directive has caused significant legal uncertainty due to its imprecise concepts and ambiguous substance indicators.
Following several years of discussions between the EU Commission and delegations of EU Member States, the draft Unshell Directive was finally abandoned on 20 June 2025.
Read the full article in French, written by our Tax Partner & Head of Transfer Pricing, Oliver R. Hoor, providing a brief overview of the Unshell Directive and the anti-abuse legislation that EU Member States can apply to tackle shell entities.