The recently proposed EU Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) for the EU includes a number measures aimed at preventing base erosion and profit shifting (BEPS), including measures based on the outcomes of various Actions of the OECD BEPS Project. The measures are summarized as follows.
General Anti-Abuse Rule
The general anti-abuse rule includes that an EU Member State will ignore an arrangement or a series of arrangements that have been put into place for …