On 17 June 2016, the EU Economic and Financial Affairs Council (ECOFIN) reached broad agreement on a revised draft of the Anti Tax Avoidance Directive, subject to a silence procedure that will end at midnight on 20 June 2016. The two main revisions include:
- Regarding the interest deduction limitation rules, EU Member States would be allowed to introduce a five-year grandfathering period for existing loans;
- Regarding the CFC rules, one of the conditions for a company to be treated as CFC is …