Implementation of the Anti-Tax Avoidance Directive and Czech Law

Abstract

The ATA Directive is one of the series of legal rules that are primarily targeted to tackle tax avoidance. The aim of the article is to firstly introduce measures that are obtained in the ATA Directive and that must be transposed into the Czech law and, secondly, to assess possible approaches to this transposition.

Keywords

• ATA Directive
• CFC Rules
• interest limitation rule
• exit tax
• hybrid mismatches
• income tax avoidance