Critical Review Of The ATAD Implementation: The Implementation of the ATAD in Greece

Abstract

This article examines the implementation of the anti-tax avoidance directive (ATAD) in Greece. It reviews the additions to and the amendments that had to be made in Greek law resulting from the implementation of the ATAD. It does so in an analytical and critical manner by exploring all of the ATAD provisions, examining the way that they were implemented into Greek law, and how they differentiate from the previous rules (if they existed at all). It examines the compatibility of the said provisions, as they have been transposed in Greece, with EU law and their compatibility with the Greek Constitution, especially in relation to the interest limitation rule, the exit tax, and the general anti-abuse rule (GAAR) ATAD, anti-avoidance, CFC, exit taxation, GAAR, hybrid mismatches, implementation, interest limitation rule.