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

Abstract

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. Transposition, Anti Tax-Avoidance Directive (ATAD), Interest Deduction Limitation Rules, General Anti-Abuse Rule (GAAR), Controlled Foreign Company Rules (CFC rules), EBITDA, Main Purpose Test, non-Genuine Arrangement, ECJ case law, Greece