The European Commission (EC) launched on 6 July a public consultation on measures to address the role of “enablers that facilitate tax evasion and aggressive tax planning” in the European Union (Securing the Activity Framework of Enablers – SAFE). In short, the EC is asking for feedback on possible measures with regard to intermediaries that provide tax advisory services (the ‘enablers’) on complex structures that could lead to tax evasion or an aggressive tax structure. The options under consideration address the challenges linked to non-EU shell entities and include an obligation to adhere to a Code of Conduct; a requirement to undertake dedicated due diligence; and potential mandatory registration in the European Union. The consultation also raises questions about measures such as monetary penalties and loss of registration, and addresses questions on taxpayers facing a new registration requirement for certain non-listed participations located outside the European Union.
Source PwC
