ATAD – Council Directive (EU) 2016/1164 of 12 July 2016 Laying down BEPS. 1 The EU responded to BEPS by adopting anti-tax avoidance package. ATAD is

OECD har i sitt projekt Base Erosion and Profit Shifting (BEPS) tagit fram en EU:s direktiv mot skatteflykt (Anti-Tax Avoidance Directive, ATAD) innehåller

implementeringen av BEPS och ATAD, skatteeffekter av Brexit och en products (BEPS) for the thermal insulation of buildings when applied to walls,. linked to the essential requirements of the EU Construction Products Directive Cristina Trenta is an Associate Professor in Law at Örebro University. She holds a PhD in European Tax Law from the Alma Mater Studiorum University of om ändring av direktiv 2013/34/EU vad gäller offentliggörande av Särskilt genom åtgärd 13 i BEPS införs en landsspecifik rapportering för procedures; the Members States of the EU have adopted a directive on dispute changes implied by the BEPS project, the work on Pillars 1 and 2 could require Det var då som arbetet med ett nytt OECD-regelverk, BEPS, inleddes tillsammans med EU:s ATAD-direktiv (Anti-Tax Avoidance Directive) ”directive shopping”(3) är förenlig med moder-/dotterbolagsdirektivet och med projekt om urholkning av skattebasen och överföring av vinster (”BEPS”), som EU:s förteckning över icke samarbetsvilliga jurisdiktioner på skatteområdet för att genomföra åtgärder mot BEPS (Base Erosion and Profit Shifting) vars syfte är and will be automatically reported under the EU Directive 2018/822 (DAC 6). The role of the BEPS as an accelerator for corporate capital gains taxation renewals in the European Union . Kukkonen, Matti; Torkkeli, Anu Maria (2020-12-24). av O Palme — However, this fact is almost always overlooked in the current EU and OECD by the OECD's recent base erosion and profit-shifting (BEPS) measures, the can comply with such regulations without running into legal risks.

In addition, the EU provisions will also ensure that the reported information on cross-border arrangements is automatically exchanged between Member States. 2016. The directive, formally adopted by the Economic and Financial Affairs Council of the EU on 12 July 2016, aims to provide a minimum level of protection for the internal market and ensure a harmonized and coordinated approach in the EU to the implementation of some of the recommendations under the OECD BEPS project. On 20 June 2016 the Council adopted the Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market. In order to provide for a comprehensive framework of anti-abuse measures the Commission presented its proposal on 25th October 2016, to complement the existing rule on hybrid mismatches. The European Union's response to the OECD BEPS project, the Anti-Avoidance Directive (ATAD I) has brought about extensive changes to the corporate tax regimes of EU member states effective January 1, 2019, with additional measures coming down the track.

for OECD BEPS recommendations. The EU Anti-Tax Avoidance (ATA) Directive specifically includes measures addressing Actions 2 on hybrid mismatches, 3 on controlled foreign companies (CFC) and 4 on interest deductibility. The EU member states unanimously agreed to adopt this directive, and it will be gradually implemented in 2019 through 2022. The

In the EU the European Commission will publish in early 2016 an EU anti-BEPS proposal which will implement important aspects of the OECD BEPS package. The EU is also preparing EU transfer pricing guidelines. During this conference tax specialists from all over the world will discuss these important developments.

anti-BEPS measures. In the EU the European Commission will publish in early 2016 an EU anti-BEPS proposal which will implement important aspects of the OECD BEPS package. The EU is also preparing EU transfer pricing guidelines. During this conference tax specialists from all over the world will discuss these important developments.

They are laid down in Council Directive 2017/1852 of 10 October 2017 and bring a significant improvement to resolving tax disputes, as they ensure that businesses and citizens can resolve disputes related to the interpretation and application of tax treaties more swiftly and effectively.. The new rules also cover issues related to BEPS.1 The EU responded to BEPS by adopting anti-tax avoidance package.

Podcast: Credit Funds was published on 27 December 2016 and entered into force last week. The Law transposes EU Council Directive 2016/881 of 25 The EU Directive around the Automatic Exchange of Information regarding Tax Rulings issued on October 6th, 2015 is an example of an EU implementation of BEPS.
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2 These measures are to be phased in over the period from 2019 to 2022, and the EU and OECD are now both discussing further On 28 January 2016, the European Commission presented its Anti Tax Avoidance Package, one of the core pillars of which is a Draft EU Anti Tax Avoidance Directive or "Anti-BEPS" Directive. The Draft Directive proposes anti-tax avoidance rules in six specific areas, which are intended to be implemented by each EU Member State. This article provides an overview of the proposed provisions and EU Council adopts directive on automatic exchange of tax rulings, reaches conclusions on BEPS December 8, 2015 Council of the European Union , Europe , European Commission , European Council , Featured News , Liechtenstein , San Marino , Switzerland , Transfer Pricing The European Parliament's legislative train schedule monitors the progress of legislative files identified in the 10 priorities of the European Commission 2019-02-12 2016-04-28 2017-01-05 OECD BEPS and EU Anti-Tax Avoidance Directive Implications for Captive Insurers Richard Cutcher of Captive Review reported in the latest edition that EY is building a working group to lobby the OECD and ensure those writing the upcoming transfer pricing paper are fully educated on what captive insurance companies are about. Ireland’s Minister for Finance commented that the interest limitation rules in the ATA Directive “are deferred until 2024 for countries, like Ireland, that already have strong targeted rules.” 4 Ireland has sought to defer introduction of the ATA Directive interest limitation rule, which is aligned with the best practice recommendations in Action 4 of the OECD BEPS project.
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This Directive aims to achieve a balance between the need for a certain degree of uniformity in implementing the BEPS outputs across the EU and Member States' needs to accommodate the special features of their tax systems within these new rules.

WHAT ABOUT CYPRUS RESPONSE? So far, Cyprus has taken limited actions to respond to the challenges on implementing the EU and OECD proposals/action in this area.

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Sep 30, 2016 OECD BEPS Action Plan: moving from talk to action in the European EU ATA Directive and EU Code of Conduct — inbound profit transfers.

https://www.loyensloeff.com/…/dac7-approved-new-reporting-…/? 2016-02-29 · European Union: Dutch presidency issues EU-BEPS roadmap. The Netherlands, which currently holds the presidency of the council of the EU, issued an ambitious EU-BEPS “roadmap” on 19 February 2016 that sets out plans to move forward with previous EU proposals, as well as future efforts on areas relating to the OECD’s base erosion and profit shifting (BEPS) project.

Aug 21, 2017 With BEPS measures being implemented in the BEPS directives into more than 2,000 tax further strengthened by Council Directive (EU).

The focus of this thesis is the EU Directive on mandatory disclosure rules on intermediaries that make available potentially aggressive cross-border tax arrangements. Its avowed purpose is to arrest base erosion and to address fairness in taxation. It closely follows the BEPS Action 12 principles and has tioned reasons the OECD PPT rule is contrary to EU law. The only potential problem I see is that the OECD PPT rule is broader (no artificiality required) compared to the GAARs in Anti-Tax Avoidance Directive and the Parent–Subsidiary Directive. Keywords: GAAR, abuse, tax avoidance, BEPS, principal purpose test, legal certainty 1 Introduction The EU has also adopted legally binding anti-tax avoidance measures targeting hybrid mismatches (BEPS Action 2), interest deductions (BEPS Action 4), and controlled foreign companies (BEPS Action 3) and has added EU-specific rules on exit taxation and general anti-abuse. 2 These measures are to be phased in over the period from 2019 to 2022, and the EU and OECD are now both discussing further On 28 January 2016, the European Commission presented its Anti Tax Avoidance Package, one of the core pillars of which is a Draft EU Anti Tax Avoidance Directive or "Anti-BEPS" Directive. The Draft Directive proposes anti-tax avoidance rules in six specific areas, which are intended to be implemented by each EU Member State.

for OECD BEPS recommendations. The EU Anti-Tax Avoidance (ATA) Directive specifically includes measures addressing Actions 2 on hybrid mismatches, 3 on controlled foreign companies (CFC) and 4 on interest deductibility. The EU member states unanimously agreed to adopt this directive, and it will be gradually implemented in 2019 through 2022. The Purpose Test Rule in OECD BEPS Action 6 (Tax Treaty Abuse) versus the EU Principle of Legal Certainty and the EU Abuse of Law Case Law Dennis Weber* Abstract The OECD BEPS Action 6 report contains a principal pur-pose test rule (PPT rule) for the purpose of combating abuse of tax treaties. This PPT rule is also included in the OECD Multilateral Instrument. I give a short overview of the EU Anti-BEPS directive of 28 January 2016 The package includes two legislative proposals: (1) a directive addressing certain anti-base-erosion and profit-shifting (BEPS) issues; and (2) an amendment to the Directive on Administrative Cooperation in Taxation to require automatic exchange of tax rulings and information with respect to country-by-country reporting.