As US advisors this provision doesn't appear to apply to us. However, if your providing advice on using Ireland as a financing strip out vehicle for European investment or using Luxembourg as a royalty strip out vehicle for European sales; then this provision could very well apply to you!
The Special Committee on Tax Rulings said that information contained in the Panama Papers on how offshore shell companies can be used to escape tax liabilities highlights an “urgent need” for the European Union to fight tax evasion and avoidance.
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Read more at: Tax Times blog