Shell companies, Directive still on hold

There is a stalemate in the Council of the European Union on the approval of the proposal for a Directive COM(2021) 565 final (also known by the acronym 'ATAD 3'), aimed at combating the use of so-called 'shell companies' in the European context. As is well known, the initiative aims to hinder those companies, resident for tax purposes within the European Union, equipped with a so-called 'light' organisational structure (in terms, for example, of personnel, premises and equipment), not exercising an actual economic activity and lacking decision-making autonomy, but which access the tax benefits of the Treaties against double taxation and the European Directives.