By Rick Minor (February 15, 2019, 3:58 PM EST) -- On Jan. 1, 2019, the European Union Anti-Tax Avoidance Directive, or ATAD, went into effect for all 28 member states. ATAD is the European Commission's response to the relevant action plans of the base erosion profit shifting, or BEPS, project of the Organization of Economic Cooperation and Development. There are three BEPS-related rules in ATAD plus an additional two rules which did not derive from BEPS, for a total of five substantive anti-tax avoidance rules. This article provides an overview of these five areas. ATAD applies of course to the European operations of U.S. groups and certain U.S.-EU transactions within those groups. How ATAD impacts specific group structures depends on the facts and circumstances of the particular structure and the covered transactions....
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