The Implementation of Anti-BEPS legislation in the European Union: A Comprehensive Study

The Implementation of Anti-BEPS Rules in the EU: A Comprehensive Study
Providing a comprehensive technical analysis of the EU Anti-Tax Avoidance Directive, this book also offers insight on selected issues connected with the OECD BEPS Project.

Why this book?

This book is a joint effort between the Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam, its partner institutions within the Global Tax Conference Project (New York University, the University of São Paulo and the Central University of Finance and Economics of Beijing) and IBFD, in the framework of well-established bilateral scientific cooperation.

Besides providing a comprehensive technical analysis of the EU Anti-Tax Avoidance Directive (ATAD), this book offers insight on selected issues connected with the OECD Base Erosion and Profit Shifting (BEPS) Project that are important for predicting its possible impact, including on relations with non-EU Member States.

Subjects discussed in this book are:

  • EU-US relations in the field of direct taxes
  • BEPS and 3D printing
  • Patent boxes before and after BEPS Action 5
  • Tax planning and State aid
  • BEPS Action 6 and the limitation on benefits provision
  • The switch-over clause
  • BEPS Action 12, the lack of certainty and the infringement of taxpayers’ rights
  • The interest limitation rule of the ATAD
  • Exit taxation and the ATAD
  • General anti-abuse rules and the ATAD
  • Controlled foreign company (CFC) rules and the ATAD
  • The ATAD’s CFC rule and third countries
  • Hybrid mismatch rules under ATAD I & II
  • Permanent establishment mismatches under ATAD II
  • Imported mismatches

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Sample excerpt, including table of contents

Contributor(s)

Reuven Avi-Yonah, Robert Danon, Adriana De Haro, Gijs Fibbe, Alessandra Flamini, Isabella de Groot, Werner Haslehner, Christiana HJI Panayi, Fred van Horzen, Luis Olmos, Suniel Pancham, Bart Peeters, Andreas Perdelwitz, Arne Schnitger, Luís Eduardo Schoueri, Daniel Shaviro, Bruno da Silva, Daniel Smit, Edoardo Traversa, Hein Vermeulen, Maarten de Wilde, Haiyan Xu and Ivan Zavirof.

The Implementation of Anti-BEPS Rules in the EU: A Comprehensive Study
https://doi.org/10.59403/21610y2
Chapter 1: An Introduction to the Anti-Tax Avoidance Directive and the Implementation of the BEPS Project in the European Union
https://doi.org/10.59403/21610y2001
Chapter 2: The BEPS Project: Still a Military Approach
https://doi.org/10.59403/21610y2002
Chapter 3: EU-US Relations in the Field of Direct Taxes from the EU Perspective: A BEPS-Induced Transformation?
https://doi.org/10.59403/21610y2003
Chapter 4: The EU-US Relationship in the Field of Income Taxation as Viewed from a US Perspective
https://doi.org/10.59403/21610y2004
Chapter 5: BEPS, 3D Printing and the Evolution of the Manufacturing Industry
https://doi.org/10.59403/21610y2005
Chapter 6: Patent Boxes before and after BEPS Action 5
https://doi.org/10.59403/21610y2006
Chapter 7: Tax Planning and State Aid
https://doi.org/10.59403/21610y2007
Chapter 8: BEPS Action 6 and the LOB Provision: Restoring the Debate on the Compatibility with EU Law
https://doi.org/10.59403/21610y2008
Chapter 9: The Switch-Over Clause: To Exempt or Not to Exempt, That Is the Question
https://doi.org/10.59403/21610y2009
Chapter 10: BEPS Action 12: The Lack of Certainty and the Infringement of Taxpayers’ Rights
https://doi.org/10.59403/21610y2010
Chapter 11: The Transitional Period and its Impact on Tax Competition and the Implementation of the BEPS Project
https://doi.org/10.59403/21610y2011
Chapter 12: The Interest Limitation Rule
https://doi.org/10.59403/21610y2012
Chapter 13: Entrepreneurial, Corporate and Asset Emigration in Exit Taxation in the ATAD
https://doi.org/10.59403/21610y2013
Chapter 14: Is the ATAD’s GAAR a Pandora’s Box?
https://doi.org/10.59403/21610y2014
Chapter 15: Developing a Common Framework against Tax Avoidance in the European Union
https://doi.org/10.59403/21610y2015
Chapter 16: The ATAD’s CFC Rule and its Impact on the Existing Regimes of EU Member States
https://doi.org/10.59403/21610y2016
Chapter 17: Some Observations on the Carve-Out Clause of Article 7(2)(a) of the ATAD with Regard to Third Countries
https://doi.org/10.59403/21610y2017
Chapter 18: Hybrid Mismatch Rules under ATAD I & II
https://doi.org/10.59403/21610y2018
Chapter 19: Permanent Establishment Mismatches under ATAD II
https://doi.org/10.59403/21610y2019
Chapter 20: Imported Mismatches
https://doi.org/10.59403/21610y2020