European Union - Is ATAD a Black Hole? The Impact on International Tax Planning
- European Union
- T. Kollruss
- European Taxation, 2019 (Volume 59), No 8
- 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?