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Alain Huyghe

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Alain Huyghe is a partner in the Tax Practice Group of the Brussels office. He joined Baker McKenzie in 1986 and became partner in 1994. Alain has been mentioned consistently over the past 25 years as a leading tax lawyer in Belgium in publications such as the International Tax Review, Chambers and The European Legal 500.

Interested parties could, until 6 April 2022, provide their views to the EU Commission regarding the so-called Unshell proposal or ATAD 3. Many will have flagged the uncertainties about certain concepts and the need for more clarifications while others will also have indicated more substantial issues such as possible non-compatibility with EU Law. It remains to be seen whether the EU Commission will take (some of) these comments on board. Meanwhile, international groups should not rest on their laurels because it is likely that the Proposal will be adopted (as is or in an amended form) but rather start screening the European affiliates in their corporate structure, to identify possible issues under ATAD 3 and look for possible remedies.