The Resource The ATAD 2 anti-hybrid rules versus EU member state tax treaties with third states : is override possible?

The ATAD 2 anti-hybrid rules versus EU member state tax treaties with third states : is override possible?

Label
The ATAD 2 anti-hybrid rules versus EU member state tax treaties with third states : is override possible?
Title
The ATAD 2 anti-hybrid rules versus EU member state tax treaties with third states : is override possible?
Creator
Subject
Language
  • eng
  • eng
Summary
This article analyses the anti-hybrid mismatch rules applicable in respect of third countries contained in the amended EU Anti-Avoidance Directive (2016/1164) (ATAD 2). The author concludes that, in general, the Council designed ATAD 2 so as to ensure that Member States could avoid possible treaty override and preserve their obligations with third countries although, in a limited number of scenarios, treaty override could still arise
Citation source
In: European taxation. - Amsterdam. - Vol. 59 (2019), no. 2/3 ; p. 52-59
http://library.link/vocab/creatorName
Karaianov, K
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • ATAD 2
  • hybrid mismatch
  • tax treaty
  • treaty override
  • third countries (EU)
  • deductions
Label
The ATAD 2 anti-hybrid rules versus EU member state tax treaties with third states : is override possible?
Instantiates
Publication
Note
20190305
Other control number
et_2019_02_e2_3.html
Label
The ATAD 2 anti-hybrid rules versus EU member state tax treaties with third states : is override possible?
Publication
Note
20190305
Other control number
et_2019_02_e2_3.html

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      52.3736660 4.9336932
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