mot urholkning av skattebasen och överföring av vinster (BEPS), redan bekräftat att Proposal for a Council Directive laying down rules relating to the corporate Rådets direktiv (EU) 2017/2455 av den 5 december 2017 om 

We were among the first countries to sign and then ratify the BEPS Multilateral Instrument. This has significantly reduced the potential for tax treaties to be used for tax avoidance purposes. Further, we agreed the EU Anti-Tax Avoidance Directives with our fellow Member States to implement a number of the key BEPS actions consistently across

Having sound and sustainable substance a must both for BEPS and the GAAR of Parent Subsidiary directive. 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 … 2020-07-01 EU approaches highlights a need for MNEs to review its operation and, if needed, to align all its intragroup policies with new ATAD principles and rules. Among others, Group financial policies are massively impacted by ATAD and by ongoing BEPS Actions 8-10 follow-up work on transfer pricing aspects of financial transactions. The EU member states have embraced the OECD BEPS recommendations, even though some — such as Cyprus, Croatia, Malta and Romania — are not OECD members. 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.

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On December 11 2015, the draft text of the EU Anti-BEPS Directive discussed at the December ECOFIN meeting was made available to the public. existing tax regime. The directive’s aim is to ensure consistent implementation of certain anti-avoidance provisions (including some of the key OECD BEPS actions) across the EU Member States. In that sense the directive could be seen as creating a ‘level playing field’ throughout the EU. EU Council adopts directive on automatic exchange of tax rulings, reaches conclusions on BEPS December 8, 2015 Council of the European Union , Europe , European Commission , European Council , Featured News , Liechtenstein , San Marino , Switzerland , Transfer Pricing BEPS står för förkortningen Base Erosion and Profit Shifting.

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Furthermore, to the extent a fund vehicle provides internal debt, the BEPS measures concerning “ hybrid mismatches CCCTB proposal of certain provisions on the international anti-BEPS aspects with the aim to achieve a swift, consistent and coordinated implementation of OECD-BEPS recommendations in the EU. At the WPTQ meeting of 9 July 2015, most delegations supported the prospect for such a split and suggested that the "anti-BEPS directive" that 2021-01-01 EU Member States Responses on BEPS Initiatives. How do the governments of Luxembourg, EU Parent / Subsidiary Directive. The government of Cyprus is in the final stages of introducing changes in order to transpose in its own legislation the two recent amendments to the EU Parent- Subsidiary Directive… It is clear that the EU intends to follow the internationally agreed recommendations of the OECD BEPS project on CbC reporting to tax authorities.

The Directive provides broad rules but leaves the specific implementation and details up to the different EU Member States. The proposed rules will have a significant impact on how business structure their EU and also international investments and will result in an additional burden for the tax departments of MNEs, which are already stretched by the numerous recent global, EU and local changes

On December 11 2015, the draft text of the EU Anti-BEPS Directive discussed at the December ECOFIN meeting was made available to the public. existing tax regime. The directive’s aim is to ensure consistent implementation of certain anti-avoidance provisions (including some of the key OECD BEPS actions) across the EU Member States. In that sense the directive could be seen as creating a ‘level playing field’ throughout the EU. EU Council adopts directive on automatic exchange of tax rulings, reaches conclusions on BEPS December 8, 2015 Council of the European Union , Europe , European Commission , European Council , Featured News , Liechtenstein , San Marino , Switzerland , Transfer Pricing BEPS står för förkortningen Base Erosion and Profit Shifting. BEPS kommer att innebära ett större uttag av bolagsskatter och en omfördelning av beskattningsunderlaget mellan olika länder. Så påverkas svenska företag. On 28 January 2016, the European Commission presented its Anti Tax Avoidance Package, one of the core pillars of which is a Draft EU Anti Tax Avoidance Directive or "Anti-BEPS" Directive.

It closely follows the BEPS Action 12 principles and has tioned reasons the OECD PPT rule is contrary to EU law. The only potential problem I see is that the OECD PPT rule is broader (no artificiality required) compared to the GAARs in Anti-Tax Avoidance Directive and the Parent–Subsidiary Directive. Keywords: GAAR, abuse, tax avoidance, BEPS, principal purpose test, legal certainty 1 Introduction The EU has also adopted legally binding anti-tax avoidance measures targeting hybrid mismatches (BEPS Action 2), interest deductions (BEPS Action 4), and controlled foreign companies (BEPS Action 3) and has added EU-specific rules on exit taxation and general anti-abuse. 2 These measures are to be phased in over the period from 2019 to 2022, and the EU and OECD are now both discussing further On 28 January 2016, the European Commission presented its Anti Tax Avoidance Package, one of the core pillars of which is a Draft EU Anti Tax Avoidance Directive or "Anti-BEPS" Directive. The Draft Directive proposes anti-tax avoidance rules in six specific areas, which are intended to be implemented by each EU Member State. This article provides an overview of the proposed provisions and EU Council adopts directive on automatic exchange of tax rulings, reaches conclusions on BEPS December 8, 2015 Council of the European Union , Europe , European Commission , European Council , Featured News , Liechtenstein , San Marino , Switzerland , Transfer Pricing The European Parliament's legislative train schedule monitors the progress of legislative files identified in the 10 priorities of the European Commission 2019-02-12 2016-04-28 2017-01-05 OECD BEPS and EU Anti-Tax Avoidance Directive Implications for Captive Insurers Richard Cutcher of Captive Review reported in the latest edition that EY is building a working group to lobby the OECD and ensure those writing the upcoming transfer pricing paper are fully educated on what captive insurance companies are about.
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Kommissionen föreslår också ytterligare harmonisering genom.

This includes a proposal for an anti-base erosion and profit shifting (BEPS) EU directive. The proposed rules lay down common minimum rules  av M Dahlberg · 2019 — OECD och G20-gruppen arbetar med detta inom ramen för BEPS-projektet.
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On 28 January 2016 the Commission presented its proposal for an Anti-Tax Avoidance Directive as part of the Anti-Tax Avoidance Package.On 20 June 2016 the Council adopted the Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market.

ATAD is  Sep 15, 2020 Individual member states were already free to voluntarily adopt such anti-BEPS measures as they saw fit, but the EU was hoping for a cleaner  The first BEPS related action at EU level was to include a general anti-avoidance rule and a provision against hybrid mismatches in the EU Parent Subsidiary  Jul 17, 2020 Overview. The European Union (EU) introduced the Anti-Tax Avoidance Directive (EU) 2016/1164 on 12 July 2016.

Cristina Trenta is an Associate Professor in Law at Örebro University. She holds a PhD in European Tax Law from the Alma Mater Studiorum University of 

laying down rules against tax avoidance practices that directly affect the functioning of the internal market.

COUNCIL DIRECTIVE (EU) 2016/1164. of 12 July 2016. laying down rules against tax avoidance practices that directly affect the functioning of the internal market. THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on the Functioning of the European Union, and in particular Article 115 thereof, A substantive economic connection between entities claiming benefits has become increasingly important as a threshold to secure tax treaty and European Union (EU) directive benefits. 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.