Jul 21, 2020 The directive also harmonizes specific anti-avoidance mechanisms in order Keywords: EU tax Law; abuse of rights; BEPS; tax harmonization.

The focus of this thesis is the EU Directive on mandatory disclosure rules on intermediaries that make available potentially aggressive cross-border tax arrangements. Its avowed purpose is to arrest base erosion and to address fairness in taxation. It closely follows the BEPS Action 12 principles and has

The EU Anti-Tax Avoidance (ATA) Directive specifically includes measures addressing The Directive is fully compatible with BEPS. It has the added advantage of being legally binding and ensuring that all Member States apply the same measures for intermediaries. In addition, the EU provisions will also ensure that the reported information on cross-border arrangements is automatically exchanged between Member States. The focus of this thesis is the EU Directive on mandatory disclosure rules on intermediaries that make available potentially aggressive cross-border tax arrangements. Its avowed purpose is to arrest base erosion and to address fairness in taxation.

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Implementation of the recommendation via EU or national legislative actions This directive is also known as ATAD or Anti-BEPS Directive and was issued on  Learn more about pressure equipment directive 2014/68/EU and how it impacts your products. Schedule your consultation with Obelis' EU compliance experts. Following the OECDs final proposals on permanent establishments (PE), there is a growing need for multinational groups to assess where their PE risks might  Mar 28, 2019 European countries face many issues that the BEPS project was intended to The project was named Anti Tax Avoidance Directive (ATAD). Feb 7, 2016 The Directive presents anti-tax avoidance rules in six specific areas. Profit Shifting ("BEPS") package for the reform of the international tax  om ändring av direktiv (EU) 2016/1164 vad gäller hybrida missmatchningar med EESK stöder OECD:s och G20:s Beps-slutsatser och de bestämmelser som  När EU i början av 2016 presenterade sitt Anti-Tax Avoidance Package var Implementering av en så stor överenskommelse som BEPS är nästa svåra steg. av E Åkerman · 2020 — ATAD II - Anti-Tax Avoidance Directive (Direktiv 2016/1164) efter ändringarna. BEPS - Base Erosion and Profit Shift.

The recently proposed EU Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) for the EU includes a number measures aimed at preventing base erosion and profit shifting (BEPS), including measures based on the outcomes of various Actions of the OECD BEPS Project. EU Law and the Building of Global Supranational Tax Law: EU BEPS and State Aid Why this book?

Ireland’s Minister for Finance commented that the interest limitation rules in the ATA Directive “are deferred until 2024 for countries, like Ireland, that already have strong targeted rules.” 4 Ireland has sought to defer introduction of the ATA Directive interest limitation rule, which is aligned with the best practice recommendations in Action 4 of the OECD BEPS project.

The European Commission has driven the EU legislative agenda for OECD BEPS recommendations. The EU Anti-Tax Avoidance (ATA) Directive specifically includes measures addressing The Directive is fully compatible with BEPS. It has the added advantage of being legally binding and ensuring that all Member States apply the same measures for intermediaries.

for OECD BEPS recommendations. The EU Anti-Tax Avoidance (ATA) Directive specifically includes measures addressing Actions 2 on hybrid mismatches, 3 on controlled foreign companies (CFC) and 4 on interest deductibility. The EU member states unanimously agreed to adopt this directive, and it will be gradually implemented in 2019 through 2022. The

The Council agreed that a common approach to implementing BEPS at an EU level would be valuable, and concluded that EU directives should be the preferred vehicle for implementing BEPS.

I refuse cookies. 2017-03-15 5. The Presidency will aim at reaching agreement during the next months on the following EU-BEPS work items: A. Interest and Royalties Directive (IRD) 6.
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This Directive aims to achieve a balance between the need for a certain degree of uniformity in implementing the BEPS outputs across the EU and Member States' needs to accommodate the special features of their tax systems within these new rules. The European Union (EU) Directive on the mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (commonly known as DAC6) comes from the BEPS initiative, notably from the BEPS Action 12 report on the mandatory disclosure rules (MDR).

This PPT rule is also included in the OECD Multilateral Instrument. I give a short overview of the EU Anti-BEPS directive of 28 January 2016 The package includes two legislative proposals: (1) a directive addressing certain anti-base-erosion and profit-shifting (BEPS) issues; and (2) an amendment to the Directive on Administrative Cooperation in Taxation to require automatic exchange of tax rulings and information with respect to country-by-country reporting. • BEPS is a supra-EU initiative lead by the G20 and the OECD, therefore the UK’s exiting the EU should not impact the UK’s implementation of BEPS.
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It is linked with the OECD/G20 BEPS (base erosion and profit shifting) action plan . The proposal covers six legally binding anti-abuse measures, which all 

During this conference tax specialists from all over the world will discuss these important developments. The BEPS Action 13 report (Transfer Pricing Documentation and Country-by-Country Reporting) provides a template for multinational enterprises (MNEs) to report annually and for each tax jurisdiction in which they do business the information set out therein. This report is called the Country-by-Country (CbC) Report.. To facilitate the implementation of the CbC Reporting standard, the BEPS Action • BEPS is a supra-EU initiative lead by the G20 and the OECD, therefore the UK’s exiting the EU should not impact the UK’s implementation of BEPS. • The EU Commission has introduced an Anti Tax Avoidance Package that includes an Anti Tax Avoidance Directive (“ATAD”) that seeks to impart a consistent EU approach to many of the BEPS proposals.