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

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?