We support the European Commission’s proposals to ensure implementation of the OECD/G20 tackle base-erosion and profit shifting (BEPS) recommendations in the EU. Regarding the proposed measures that go beyond the OECD/G20 BEPS recommendations, we encourage the Commission to carefully assess the impact of these provisions to ensure they are effective, maintain a level playing field, and do not unnecessary burden the EU economy.

We recommend EC to do impact assessments on non-BEPS provisions and suggest to revise its decision to include non-group companies in the Directive’s scope. The €1 million threshold for the interest limitation rule is too low and the inclusion of non-group companies in these provisions could be very damaging for some companies. We underline the difficulty and the potential unintended consequences of establishing a common approach on exit taxes as well as the potential negative consequences of the switch-over clause.

 Comment letter to European Commission on Anti-Tax Avoidance Directive