Implementing The Revised Parent Subsidiary Directive Across The EU

A striking example of the EU's efforts to accelerate the implementation of anti-base erosion and profit shifting (BEPS) measures is the amended Parent Subsidiary Directive (PSD). Originally designed to prevent economic double taxation of profits distributed within an EU corporate, the PSD is now also being deployed to counter undesired tax planning within the EU by requiring member states to implement in their domestic laws by 31 December 2015 both a general anti-abuse provision (AAP) and a specific anti-hybrid rule. The amendments raise important implementation questions which could result in domestic tax laws varying considerably. Enough reason for making a comparison of the legislative changes and proposals implementing the amendments to the PSD in major EU member states, and Switzerland.