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The Withdrawal of the ATAD 3 Directive – An Analysis of Attempts to Define the Required Physical Substance of EU Holding Companies

Jakub Jankowski

European Taxation2026https://doi.org/10.59403/2j4vqxfarticle
ABDC B
Weight
0.50

Abstract

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.

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https://doi.org/https://doi.org/10.59403/2j4vqxf

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@article{jakub2026,
  title        = {{The Withdrawal of the ATAD 3 Directive – An Analysis of Attempts to Define the Required Physical Substance of EU Holding Companies}},
  author       = {Jakub Jankowski},
  journal      = {European Taxation},
  year         = {2026},
  doi          = {https://doi.org/https://doi.org/10.59403/2j4vqxf},
}

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The Withdrawal of the ATAD 3 Directive – An Analysis of Attempts to Define the Required Physical Substance of EU Holding Companies

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Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.