A.T.A.D.3 adds a layer of complexity to an increasingly complex tax world. To illustrate, the rules under the Unshell Directive appear clear, but are nothing short of ambiguous. Moreover, certain elements of the A.T.A.D.3 analysis depend heavily on the facts and circumstances of the case, which often are not binary. Many questions are raised, and the answers affect the way operations will be carried out. Is an entity affected by A.T.A.D.3? What is A.T.A.D.3’s expected impact on a structure? Should an entity report as a shell entity in its tax return? Can a position be improved and is it worthwhile to do so? Firm answers do not come easily and nuanced responses by advisers often mean one thing to the adviser and another thing to the client. In their article, Stephan Kraan and Mark van Casteren, Partners in Huygens Quantitative Tax Consulting, Amsterdam, suggest that the proper approach involves quantitative analysis rather than qualitative advice. The goal is to adopt a statistical approach to evaluate potential results based on probability. At that point, rational decisions can be made by management and advisers. It is a fascinating read.