ATAD I & II refer to the European Council Directive (EU) 2016/1164 of 12 July 2016 on combating tax avoidance practices (“ATAD I”), as amended by Directive (EU) 2017/952 of 29 May 2017 (“ATAD II”).
The Directives contain anti-avoidance measures such as the interest limitation rule, CFC rules and hybrid tax arrangements rules, which EU Member States were required to implement. AIQUNITED analyzes whether any of such rules may be applicable to your investment structure and advises on alternative structures.