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European Union - Is ATAD a Black Hole? The Impact on International Tax Planning

Country:
European Union
Author:
T. Kollruss
Issue:
European Taxation, 2019 (Volume 59), No 8
Published:
9 July 2019
This article examines the impact of the EU Anti-Tax Avoidance Directive (2016/1164) (ATAD) on international tax planning. Is ATAD a black hole in the tax planning universe, absorbing almost every possibility, especially double non-taxation and hybrid mismatches? Do the regulations on hybrid mismatches have a limited 2D effect? Does international tax planning need to be redefined in the ATAD era and what is the solution?
 
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