Adoption of rules against tax avoidance practices

On 5 April 2019, the House of Representatives voted into law the provisions of the European Council Directive for the adoption of rules against tax avoidance practices that directly affect the functioning of the internal market (known as Anti-Tax AvoidanceDirective – ATAD).

The anti-tax avoidance measures which were voted are:

  1. Interest limitation rule
  2. General anti-abuse rule
  3. Controlled Foreign Company rule
  4. Exit taxation
  5. Rule to tackle hybrid mismatches

The application dates for the above are:

1 January 2019: Interest limitation rule, general anti-abuse
rule and controlled foreign companies rule.

1 January 2020: Exit taxation and rule to tackle hybrid
mismatches (reverse hybrid rules shall apply by 1 January 2022).