Abstract
Last year, the Council of the European Union adopted a directive, which imposes a duty to report certain tax optimization schemes. The directive stipulates, which properties of the tax optimization scheme result in the duty to report the scheme, what information must be reported and who bears the reporting duty.
However, the directive does not stipulate, what the tax optimization scheme really is. Therefore, after the proposed measure will come into force, one can expect to encounter severe problems related to its application.
The topic of this article answers the question of what the tax optimization scheme most likely is and is not.