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The implementation of the ATAD by Austria Stefanie Geringer

By: Geringer, Stefanie.
Material type: ArticleArticleSubject(s): ELUSION FISCAL | EVASION FISCAL | PREVENCIÓN | ATAD | APLICACION | AUSTRIA In: Intertax v. 50, issue 4, April 2022, p. 356-366Summary: The Anti-Tax Avoidance Directive (ATAD) and ATAD II had major implications for the Austrian corporate tax regime. Particularly, Austria was obligated to introduce an interest limitation rule, a controlled foreign company (CFC) rule, and comprehensive hybrid mismatches rules. This article provides an overview of the transposition measures, and shows the deviations from the ATAD’s standards in Austria.
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Resumen.

The Anti-Tax Avoidance Directive (ATAD) and ATAD II had major implications for the Austrian corporate tax regime. Particularly, Austria was obligated to introduce an interest limitation rule, a controlled foreign company (CFC) rule, and comprehensive hybrid mismatches rules. This article provides an overview of the transposition measures, and shows the deviations from the ATAD’s standards in Austria.

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