Abstract
The EU Anti-Tax Avoidance (ATA) Directive of 12 July 2016 introduced common minimum standards for fighting tax avoidance practices by the Member States of the EU. Besides interest limitation rules, rules on exit taxation, general anti-abuse rules as well as measures against hybrid mismatches, the ATA Directive provides minimum standards for the treatment of Controlled foreign corporations (CFCs). It is evident that the respective provisions follow, at least partly, the handwriting of the German CFC Rules, which are the oldest within the European Union (EU) and rank among the oldest in the world. In this context, the following article critically reviews the provisions of the ATA Directive regarding CFC Rules, taking into account the experience with the German CFC legislation.
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