On 12 July 2016, the EU Economic and Financial Affairs Council (ECOFIN) formally adopted the Anti Tax Avoidance Directive. The Directive includes anti-avoidance rules in five areas based on outcomes of Actions 2, 3 and 4 of the OECD BEPS Project and certain other BEPS-related measures:
- Interest limitation rules;
- Exit taxation rules;
- A general anti-abuse rule (GAAR);
- Controlled foreign company (CFC) rules; and
- Hybrid mismatch rules.
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