On 20 June 2014, the ministers of the EU Economic and Financial Affairs Council announced that they have agreed to amend EU tax rules in order to close a loophole that allows cross-border corporate groups to benefit from double non-taxation through hybrid financing arrangements.
The amendment applies to the EU parent-subsidiary directive (2011/96/EU), which was implemented to ensure that profits from cross-border groups are not subject to double taxation. The directive requires EU Member Sta…