peer reviewedThis short chapter analyses the relationship between the interest limitation rules laid down in the Anti-Tax Avoidance Directive (ATAD) and the Proposed Directive on a Common Corporate Tax Base (CCTB). Both are substantially congruent with very few differences in their content. Nevertheless, there are several aspects of the relationship between the two directives that raise fundamental questions as to their respective impacts on national law. Accordingly, this contribution aims to highlight, first, the general relationship between European Union (EU) directives, second, the specific relationship between the ATAD and the CCTB – if and when it is adopted – and, third, comments on the few variations in their respective provisions ...
Unlike other previous EU Directives in the field of direct taxation, the Anti-Tax Avoidance Directiv...
The primary aim of this article is to question whether the general anti-abuse rule (GAAR) of Anti-Ta...
European Union (EU) law has played a key role in enforcing the EU BEPS agenda, while also introducin...
This short chapter analyses the relationship between the interest limitation rules laid down in the ...
In this contribution, the authors provide an overview of the implementation of the EU Anti-Tax Avoid...
Under the BEPS action 4, the suggested best approach gives guidelines on how Member States can imple...
The EU has adopted to the anti-tax avoidance package to implement the OECD action plan on Base Erosi...
The Anti-Tax Avoidance Directive (ATAD-1) is perhaps the most important achievement so far by the Eu...
This thesis addresses Art. 4 ATAD and looks at it from two different angles. Firstly, Art. 4 ATAD wi...
In this article, the author critically evaluates the interest deduction limitations included in the ...
Corporate income tax deductibility of interest after the implementation of ATAD Over the past few ye...
This thesis analyses whether there is a necessity to have two different CFC regimes in two legislati...
EU anti-tax avoidance critically compared to OECD approachEU anti-tax avoidance critically compared ...
The aim of the thesis is to describe and evaluate the Czech implementation of Anti-Tax Avoidance Dir...
The aim of my thesis is through comparative analysis find the differences between the newly proposed...
Unlike other previous EU Directives in the field of direct taxation, the Anti-Tax Avoidance Directiv...
The primary aim of this article is to question whether the general anti-abuse rule (GAAR) of Anti-Ta...
European Union (EU) law has played a key role in enforcing the EU BEPS agenda, while also introducin...
This short chapter analyses the relationship between the interest limitation rules laid down in the ...
In this contribution, the authors provide an overview of the implementation of the EU Anti-Tax Avoid...
Under the BEPS action 4, the suggested best approach gives guidelines on how Member States can imple...
The EU has adopted to the anti-tax avoidance package to implement the OECD action plan on Base Erosi...
The Anti-Tax Avoidance Directive (ATAD-1) is perhaps the most important achievement so far by the Eu...
This thesis addresses Art. 4 ATAD and looks at it from two different angles. Firstly, Art. 4 ATAD wi...
In this article, the author critically evaluates the interest deduction limitations included in the ...
Corporate income tax deductibility of interest after the implementation of ATAD Over the past few ye...
This thesis analyses whether there is a necessity to have two different CFC regimes in two legislati...
EU anti-tax avoidance critically compared to OECD approachEU anti-tax avoidance critically compared ...
The aim of the thesis is to describe and evaluate the Czech implementation of Anti-Tax Avoidance Dir...
The aim of my thesis is through comparative analysis find the differences between the newly proposed...
Unlike other previous EU Directives in the field of direct taxation, the Anti-Tax Avoidance Directiv...
The primary aim of this article is to question whether the general anti-abuse rule (GAAR) of Anti-Ta...
European Union (EU) law has played a key role in enforcing the EU BEPS agenda, while also introducin...