Anti-Tax Avoidance Directive (ATAD)
This Directive lays down rules against tax avoidance in order to protect the EU internal market from base erosion and profit shifting practices that directly affect it. It sets a minimum level of protection for all taxpayers subject to corporate tax in one or more Member States, through measures including interest limitation, exit taxation, a general anti-abuse rule, controlled foreign company rules and hybrid mismatch rules, to ensure that tax is paid fairly and effectively where profits are generated.
Timeline
- 8 Aug 2016Entry into force
- 31 Dec 2018AuthoritiesMember State transposition deadline
- 1 Jan 2019Interest limitation rules apply
- 31 Dec 2019Exit taxation transposition deadline
- 1 Jan 2020Exit taxation rules apply
- 9 Aug 2020AuthoritiesDeadline for the Commission's evaluation report
- 1 Jan 2024AuthoritiesApplication deadline for Member States with existing targeted rules (BEPS)
Key facts
- Reference
- Directive (EU) 2016/1164
- Adopted
- 12 Jul 2016
- Published
- 19 Jul 2016
- Status
- In force
- Topic
- ESG & Governance
- Industries
- Cross-sector, Financial Services
Main compliance requirements
Paid members only
The main compliance requirements, applicability questions and penalties are available in the ZC Smart Compliance Hub. Paid members and clients can sign in to the Hub to view them.
Related legislation
- Builds on the 15 actions of the OECD Base Erosion and Profit Shifting (BEPS) project
- related to Article 115 of the Treaty
- involves Article 8 of the Charter of Fundamental Rights of the European Union and the personal data protection provisions of Directive 95/46/EC
- related to the provisions on mutual assistance in tax matters of Directive 2010/24/EU.
Official sources
Council Directive (EU) 2016/1164 laying down rules against tax avoidance practices