What Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (ATAD) requires
This directive establishes minimum standards for EU Member States to counter corporate tax avoidance by implementing five legally binding anti-abuse measures: an interest limitation rule (Article 4), exit taxation rules (Article 5), a general anti-abuse rule (GAAR) (Article 6), controlled foreign company (CFC) rules (Articles 7 & 8), and rules to tackle hybrid mismatches (Article 9). It applies to all taxpayers subject to corporate tax in one or more Member States, including permanent establishments of third-country entities.
Pillar: Tax & Transfer Pricing · Authority: Council of the European Union · Version: 1.0.0 · Last updated:
Primary source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016L1164
SHA-256 integrity: 85a8c75023ffeab03e956920737bd2426c1f05ed05da795661f68946b8ab656c
Primary Citations — 7 traced to source
- Council Directive (EU) 2016/1164, Article 4 - Interest limitation rule
- Council Directive (EU) 2016/1164, Article 5 - Exit taxation
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