Richard Cornelisse


The Anti Tax Avoidance Package is part of the Commission's ambitious agenda for fairer, simpler and more effective corporate taxation in the EU. The Package contains concrete measures to prevent aggressive tax planning, boost tax transparency and create a level playing field for all businesses in the EU. It will help Member States take strong and coordinated action against tax avoidance and ensure that companies pay tax wherever they make their profits in the EU.


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Key elements


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Chapeau Communication


The Chapeau Communication outlines the political, economic and international context of the Anti Tax Avoidance Package and gives an overview of the different elements.


Anti Tax Avoidance Directive


The Anti Tax Avoidance Directive proposes six legally-binding anti-abuse measures, which all Member States should apply against common forms of aggressive tax planning. It aims to create a minimum level of protection against corporate tax avoidance throughout the EU, while ensuring a fairer and more stable environment for businesses.


The proposed Directive sets out six key anti tax avoidance measures, which all Member States should apply:

  • Interest limitation rule
  • Exit taxation
  • Switch-over clause
  • General anti-abuse rule
  • Controlled foreign company legislation
  • Hybrid mismatches

Click to access Anti Tax Avoidance Directive2


Revision of the Administrative Cooperation Directive


The revised Directive proposes country-by-country reporting between Member States' tax authorities on key tax-related information on multinationals operating in the EU. These new transparency provisions will allow all Member States the information that they need to detect and prevent tax avoidance schemes.



The recommendation on Tax Treaties


The Recommendation advises Member States how to reinforce their tax treaties against abuse by aggressive tax planners, in an EU-law compliant way. It covers the introduction of general anti-abuse rules in tax treaties and the revision of the definition of permanent establishment.



Communication on an External Strategy for Effective Taxation


The External Strategy presents a stronger and more coherent EU approach to working with third countries on tax good governance matters. It also sets out a process to create a common EU list of third countries for tax purposes.


External Strategy for effective communication document 1



External Strategy for effective communication document 2



Study on Aggressive Tax Planning


The study looks at Member States' corporate tax rules (or lack thereof) that can facilitate aggressive tax planning and key structures used by companies to avoid taxation. It includes factsheets with the main findings for each Member State and examples of tactics used by multinationals to lower their taxes.



The anti-tax avoidance package and other EU and international developments: Scrutiny and democratic control by national parliaments



EU links



Related GITM articles



Written by Richard Cornelisse


I advise multinational businesses in improving the efficiency and effectiveness of their Indirect Tax Function and Tax Control Framework.

I started my career as a manager at Arthur Andersen and then became a partner in EY where I led the indirect tax performance team for Netherlands and Belgium. Currently I am a senior managing director of Phenix Consulting.

I have over 20 years’ experience advising clients on international VAT issues. I am specialized in the tax aspects of financial transformations, shared service centre migration, and post merger integration work. I am also somewhat of a mentor, giving back to the profession. If you are interested in conversation and discussion, please feel free to contact me.


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Compliant tax software solutions for the global management of tax processes


In essence, HRMC’s increases its expectations towards large businesses with regard to a more and more transparent tax management strategy. However, the publication of a tax strategy will clearly not be sufficient. It is just the starting point for the provision of a clear picture about the risk management and controls in place of tax relevant processes. The daily management turns on the radar.


State-of-the-art tax compliance management software is required.


In difference hereto, the view into the current daily practice provides a different and non-compliant picture:


Widespread use of Excel spreadsheets, decentralized storage of tax relevant documents, lack of documented controls, lack of automation, global lack of tax compliance software tracking individual changes and filings, lack of standardized reports immediately available upon request, lack of in-built double-checks for the calculation of current and deferred taxes on reporting entity level, lots of tax relevant data stored at external outsourcers (e.g. external tax advisors and accounting firms), several tax software tools in place at various locations which are neither interfaced among each other and with the ERP systems in place, etc.


It is obvious that tax departments which are not adapting its process management to the requirements addressed by HMRC and other tax authorities may struggle with regard to compliance, efficiency and transparency.


Compliant tax software solutions for the global management of tax processes


In essence, HRMC’s increases its expectations towards large businesses with regard to a more and more transparent tax management strategy. However, the publication of a tax strategy will clearly not be sufficient. It is just the starting point for the provision of a clear picture about the risk management and controls in place of tax relevant processes. The daily management turns on the radar.


State-of-the-art tax compliance management software is required.


In difference hereto, the view into the current daily practice provides a different and non-compliant picture:


Widespread use of Excel spreadsheets, decentralized storage of tax relevant documents, lack of documented controls, lack of automation, global lack of tax compliance software tracking individual changes and filings, lack of standardized reports immediately available upon request, lack of in-built double-checks for the calculation of current and deferred taxes on reporting entity level, lots of tax relevant data stored at external outsourcers (e.g. external tax advisors and accounting firms), several tax software tools in place at various locations which are neither interfaced among each other and with the ERP systems in place, etc.


It is obvious that tax departments which are not adapting its process management to the requirements addressed by HMRC and other tax authorities may struggle with regard to compliance, efficiency and transparency.


Therefore, compliant tax software solutions for integrated tax management like the U² software from Universal Units become more and more important


U2 products

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