On 12 July 2016, the EU Economic and Financial Affairs Council (ECOFIN) formally adopted the Anti Tax Avoidance Directive. The Directive includes anti-avoidance rules in five areas based on outcomes of Actions 2, 3 and 4 of the OECD BEPS Project and certain other BEPS-related measures:

• Interest limitation rules;
• Exit taxation rules;
• A general anti-abuse rule (GAAR);
• Controlled foreign company …