KPMG report: Implementation of ATAD I and II by EU Member States

A report based on a survey of KPMG member firms in the EU

A report based on a survey of KPMG member firms in the EU

KPMG’s EU Tax Centre released a report, based on a survey of KPMG member firms in the EU, on the implementation of the five measures included in the Anti-Tax Avoidance Directive (ATAD I) Council Directive (EU) 2016/1164 and the Anti-Tax Avoidance Directive (ATAD II) Council Directive (EU) 2017/952, into the domestic laws of the various EU Member States.

Read the KPMG report [PDF 1 MB] (June 2022)


ATAD I and II contain five specific measures:

  • Article 4: Interest limitation rules
  • Article 5: Exit taxation rules
  • Article 6: General anti-abuse rules (GAAR)
  • Articles 7 & 8: Controlled foreign company (CFC) rules
  • Article 9: Anti-hybrid mismatch rules

Across the EU, Member States had a deadline of 1 January 2019 to introduce the interest limitation, GAAR and CFC measures. A deadline of 1 January 2020 applied in relation to exit taxation and the majority of the anti-hybrid mismatch provisions.


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