The G20 clamp down on base erosion and profit sharing, as well as the new US administration's anticipated tax proposal on repatriation of overseas income means that every multinational US corporate tax team is reviewing the European tax structures put in place over the last few years.

2017 and 2018 will see numerous cross border restructurings and a significant increase in breaking down jurisdictional structures and more focus on substance and control. Branches may become the preferred structure with an increased use of EU cross border mergers rules. 

Luxembourg holding companies and Swiss principal structures will be scrutinised by tax authorities to show substance. Where companies can't show substance, they will move structures to other jurisdictions including the UK and Ireland.

Expect a busy two years as historic tax structures are unwound.