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Private equity sponsors acquiring EU investment firms through third-country holding structures face complex regulatory architecture decisions under the Investment Firms Regulation and Directive. While there is no automatic EU intermediate holding company requirement, national competent authorities possess discretionary powers to mandate one where effective group-level supervision is absent, creating potential 'regulatory architecture debt' that accumulates with each successive acquisition.

On 5 October 2021 the ECOFIN Council updated the EU list of third country ‘non-cooperative jurisdictions for tax purposes' and also updated the EU list of third country ‘cooperative jurisdictions for tax purposes subject to ...