This book is a joint effort between the Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam, its partner institutions within the Global Tax Conference Project (New York University, the University of São Paulo and the Central University of Finance and Economics of Beijing) and IBFD, in the framework of well-established bilateral scientific cooperation.
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.
Subjects discussed in this book are:
- EU-US relations in the field of direct taxes
- BEPS and 3D printing
- Patent boxes before and after BEPS Action 5
- Tax planning and State aid
- BEPS Action 6 and the limitation on benefits provision
- The switch-over clause
- BEPS Action 12, the lack of certainty and the infringement of taxpayers’ rights
- The interest limitation rule of the ATAD
- Exit taxation and the ATAD
- General anti-abuse rules and the ATAD
- Controlled foreign company (CFC) rules and the ATAD
- The ATAD’s CFC rule and third countries
- Hybrid mismatch rules under ATAD I & II
- Permanent establishment mismatches under ATAD II
- Imported mismatches
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Includes contributions by Reuven Avi-Yonah, Robert Danon, Adriana De Haro, Gijs Fibbe, Alessandra Flamini, Isabella de Groot, Werner Haslehner, Christiana HJI Panayi, Fred van Horzen, Luis Olmos, Suniel Pancham, Bart Peeters, Andreas Perdelwitz, Arne Schnitger, Luís Eduardo Schoueri, Daniel Shaviro, Bruno da Silva, Daniel Smit, Edoardo Traversa, Hein Vermeulen, Maarten de Wilde, Haiyan Xu and Ivan Zavirof.
