EU ATAD 1 Explained: A Deep Dive into the EU's Anti-Tax Avoidance Framework

In this comprehensive lecture, we dive deep into the European Union's Anti-Tax Avoidance Directive (ATAD 1), exploring its origins, objectives, and the core measures designed to curb aggressive tax planning. Starting with its policy context and alignment with OECD BEPS, we then dissect each of the directive's five main categories-interest limitation rules, exit taxation, the general anti-abuse rule (GAAR), controlled foreign company (CFC) rules, and hybrid mismatches. We also clarify how ATAD 2 expanded the rules on hybrid mismatches to third countries. Through detailed explanations and practical examples, you'll gain a thorough understanding of how ATAD 1 harmonizes anti-abuse measures across Member States and enhances fairness, transparency, and integrity in the EU tax system. By the end of this lecture, you'll appreciate how ATAD 1 sets a precedent for future EU tax initiatives.

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