The Impact of the ATAD on Domestic Systems: A Comparative Survey

Abstract

This article provides an analysis of the Anti-Tax Avoidance Directive (2016/1164) of 12 July 2016. Following a discussion of the Directive’s main features (the interest limitation, exit taxation, general anti-avoidance, CFC and hybrid mismatch rules), a survey is provided of the impact of the Directive on the tax systems of various Member States. It concludes with a comparative analysis and reflections on the manner in which the Directive will be transposed by the Member States.