In recent years, the European Union has intensified its efforts to combat the abusive use of corporate structures lacking real substance, particularly in the tax domain. In this context, the ATAD III Directive proposal emerged, aimed at limiting the tax benefits of so-called “shell companies”. Although its implementation would have significantly impacted holding entities such as Spanish ETVEs, the project was ultimately abandoned in June 2025. This document analyzes the scope of the proposal, its implications, and current recommendations for groups with international structures.

The Colombian Tax Office (“DIAN”) and the Superintendence of Companies have entered into an inter-administrative agreement for the exchange of information related to the Ultimate Beneficial Owner Registry, to strengthen the inspection and control functions of these entities and their investigative powers.