Her first doctoral dissertation was awarded the 2008 tax law thesis award by the European Commission and European Tax Law Professors 

Based on the OECD’s BEPS recommendations, the EU Anti-Tax Avoidance Package (ATAP) aims to ensure that member states take a co-ordinated stance both in the implementation of the BEPS project and against tax avoidance. ATAP is structured around the following 4 elements: - A proposal for an Anti-Tax Avoidance Directives (ATADs)

EU leaders reiterated their commitment to reaching a consensus-based global solution on international digital taxation within the framework of the OECD by mid-2021. They confirmed, however, that the EU would be ready to move forward if the prospect of a global solution was not forthcoming. 2018-04-12 · To help ensure that Member States issue provisions that effectively limit these inconsistencies, the BEPS directive provides that the legal classification of an instrument or a hybrid company of the Member State in which a payment, expenditure or loss originates is recognized by the other Member State affected by this inconsistency. 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. 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. as BEPS). The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes.

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EU anti-BEPS: Council Directive on Rules Against Corporate Tax Avoidance (ATAD) Published 02.11.2020 State of play: 19 July 2016 published in the Official Journal (L 193/1) Details of Draft EU Anti-BEPS Directive Released Background The initiative should be seen in the context of the EU Commission's Action Plan for Fair and Efficient Corporate Taxation, launched in June 2015. 2016-02-29 · European Union: Dutch presidency issues EU-BEPS roadmap. The Netherlands, which currently holds the presidency of the council of the EU, issued an ambitious EU-BEPS “roadmap” on 19 February 2016 that sets out plans to move forward with previous EU proposals, as well as future efforts on areas relating to the OECD’s base erosion and profit shifting (BEPS) project. EU Law and the Building of Global Supranational Tax Law: EU BEPS and State Aid Why this book? The papers in this book are the result of the 10th Annual Conference of the Group for Research on European and International Taxation (GREIT), which was held on 17 and 18 September 2015 in Amsterdam. The 28 EU member states have committed to take a coordinated approach on all the items listed above. At the same time, some EU and non-EU countries have started implementing elements of the OECD BEPS recommendations unilaterally.

anti-BEPS measures. In the EU the European Commission will publish in early 2016 an EU anti-BEPS proposal which will implement important aspects of the OECD BEPS package. The EU is also preparing EU transfer pricing guidelines. During this conference tax specialists from all over the world will discuss these important developments.

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). EU Council adopts directive on automatic exchange of tax rulings, reaches conclusions on BEPS.

The EU Directive around the Automatic Exchange of Information regarding Tax Rulings issued on October 6th, 2015 is an example of an EU implementation of BEPS. Currently EU member states share little information with each other on tax rulings and advance pricing agreements, however, in the wake of BEPS (and LuxLeaks) this has been changing.

Sverige verkar för minimibeskattning inom OECD BEPS 2.0 samt 119 Lag (2017:631) om registrering av verkliga huvudmän baserat på DIRECTIVE (EU). To help ensure that Member States issue provisions that effectively limit these inconsistencies, the BEPS directive provides that the legal classification of an instrument or a hybrid company of the Member State in which a payment, expenditure or loss originates is recognized by the other Member State affected by this inconsistency. 6. 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.

However BEPS offers optional territorial approach while EU has introduced a ’one size fits all’ approach encompassing CFCs in third countries. EU ATAD is generally in line with BEPS recommendation. Contrary to BEPS no extension to third countries. EU Anti Tax Avoidance Directive Exit Taxes GAAR CFC Rules Hybrid Mismatches The European Union's response to the OECD BEPS project, the Anti-Avoidance Directive (ATAD I) has brought about extensive changes to the corporate tax regimes of EU member states effective January 1, 2019, with additional measures coming down the track.
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The 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 reflecting BEPS initiative, EU Directive July 7, 2016 In brief On May 31, 2016, the German Federal Ministry of Finance published a ministerial draft bill intended to implement certain recommendations resulting from the OECD BEPS project and also the provisions of the European Union Mutual Assistance Directive. EU moves forward on BEPS Over the past few years, the European Commission (EC) has undertaken consultations and proposed new legislation and guidance in a number of areas that overlap with the OECD’s Action Plan items.

Erosion and Profit Shifting), utarbetat ett direktiv för att säkerställa ett minimiskydd  importance for tax treaties and conflict areas with national constitutional law and EU Law. IFA-rapport, assessing BEPS: origins, standards, and responses. 10th GREIT Annual Conference - EU BEPS; Fiscal transparency, Protection of Taxpayer Rights and State Aid – 17 and 18 September 2015 - Amsterdam.
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EU Directive proposals would widen public country -by-country reporting. March 11, 2021 . In brief The EU Member States’ negotiating mandate on public country -by-country reporting (public CbCR) was established under the Portuguese Presidency of the Council on the basis of its compromise draft

It noted that several legislative proposals linked to the BEPS agenda are currently under discussion in the Council, notably the proposal for a Common Consolidated Corporate Tax Base (CCCTB) and the recast of the Interest and Royalties Directive (IRD). 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 2018-06-22 · EU countries including the Netherlands need to have the legislation to implement the Directive by 31/12/2019 and the automatic exchange will take place by 1/07/2020. I argued that the Netherlands as other EU countries will have some challenges mainly due to the broader concepts of the mandatory disclosure (e.g. what to report, when to report, and also how to deal with professional privilege).