On 20 December 2018, the Government of Gibraltar published the Income Tax 2010 (Amendment No. 3) Regulations 2018, which provide for the implementation of the EU Anti-Tax Avoidance Directive (ATAD). The regulations include the ATAD interest limitation rules, controlled foreign company (CFC) rules, and hybrid mismatch rules. The ATAD exit tax rules will be implemented separately in the future and the ATAD GAAR will not be implemented, as Gibraltar’s current GAAR is considered sufficient.
I…