The Impact of the Transposition of the ATAD on the Greek Tax System

• Autores: Petros Pantazopoulos, Katerina Kalampaliki
• Localización: Intertax, ISSN 0165-2826, Vol. 48, Nº. 2, 2020, págs. 233-249
• Idioma: inglés
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• Resumen

  • In response to the Anti-Tax Avoidance Directive (ATAD), Greece has recently amended its legislation with L. 4607/2019 regarding interest deduction limitation rules, controlled foreign company (CFC) rules, and the General Anti-Abuse Rule (GAAR). In this article, the impact of the transposition of the ATAD in the aforementioned three rules will be analysed. In addition, a comparative survey between them and the respective provisions of the ATAD will occur in which it will be examined to what extent the aforesaid anti-tax avoidance rules have been changed by the transposition of the ATAD. Lastly, a critical analysis of each of them will take place concerning the issues that may arise and on their compatibility with ECJ case law.