A majority of EU Member States reportedly support a two-step approach to the implementation of the so-called unshell proposal first proposed by the European Commission in 2021, which included measures to essentially provide that shell companies with no or minimal economic activity will be unable to benefit from any tax advantages. The Spanish presidency of the EU Council recently proposed two options to move forward with the proposal in light of an apparent deadlock in negotiations on the latest compromise text of the original proposal. The first option would be to continue negotiations on the compromise text. The second option...