On 27 January 2015, the Council of the European Union formally adopted an anti-abuse rule for the Parent-Subsidiary Directive (2011/96/EU). The rule is implemented by replacing Article 1, paragraph 2 of the Directive with the following:
“2. Member States shall not grant the benefits of this Directive to an arrangement or a series of arrangements that, having been put into place for the main purpose or one of the main purposes of obtaining a tax advantage which defeats the object o…