2020 • In Bizioli, Gianluigi; Grandinetti, Mario; Parada, Leopoldoet al. (Eds.) Corporate Taxation, Group Debt Funding and Base Erosion - New Perspectives on the EU Anti-Tax Avoidance Directive
[en] This short chapter analyses the relationship between the interest limitation rules laid down in the Anti-Tax Avoidance Directive (ATAD) and the Proposed Directive on a Common Corporate Tax Base (CCTB). Both are substantially congruent with very few differences in their content. Nevertheless, there are several aspects of the relationship between the two directives that raise fundamental questions as to their respective impacts on national law. Accordingly, this contribution aims to highlight, first, the general relationship between European Union (EU) directives, second, the specific relationship between the ATAD and the CCTB – if and when it is adopted – and, third, comments on the few variations in their respective provisions on interest limitation.
Disciplines :
Tax law European & international law
Author, co-author :
HASLEHNER, Werner ; University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit
External co-authors :
no
Language :
English
Title :
The ATAD and the CCTB
Publication date :
January 2020
Main work title :
Corporate Taxation, Group Debt Funding and Base Erosion - New Perspectives on the EU Anti-Tax Avoidance Directive
Editor :
Bizioli, Gianluigi
Grandinetti, Mario
Parada, Leopoldo
Vanz, Giuseppe
Vicini Rochetti, Alessandro
Publisher :
Kluwer Law International, Alphen aan den Rijn, Netherlands
