Background -

The Commission has published a proposal for a Council Directive, the ‘Anti Tax Avoidance Directive’ (the “Proposed Directive”), confirming the Commission’s intention to combat tax avoidance and to coordinate effectively Member States’ efforts in this area. The Proposed Directive represents a significant move regarding direct taxation within the EU.

The Proposed Directive includes recommendations in six specific areas which will apply to all taxpayers subject to corporate tax in any Member State (including taxpayers which are permanent establishments of corporate taxpayers not resident within the European Union).