European Commission proposes amendments to Parent-Subsidiary Directive by introducing anti-hybrid clause and general anti-abuse provision

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On 25 November 2013, the European Commission (the Commission) issued a proposal (the Proposal) for an amendment to the EU Parent-Subsidiary Directive (the Directive). The essential elements of the Proposal are (i) a “linking rule” that is supposed to deal with hybrid loan arrangements and (ii) a more detailed general anti-abuse rule (GAAR).

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