INTERNATIONAL TAX PLAZA - Stapled structure

Details: Published: 05 February 2022

For the purpose of Article 35 of the proposed EU Directive, the following definition applies:

‘Stapled structure’ means an arrangement under which:

(i) 50 % or more of the ownership interests in the ultimate parent entities of separate groups which, if they are listed, are quoted at a single price, and are, by reason of form of ownership, restrictions on transfer, or other terms or conditions, combined with each other, and cannot be transferred or traded independently; and

(ii) one of the ultimate parent entities prepares consolidated financial statements in which the assets, liabilities, income, expenses and cash flows of entities in all of the groups concerned are presented together as those of a single economic unit.

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