Publication date: 20 May 2016
Subject: Proposed Anti-Tax Avoidance Directive
I refer to our letter dated 21 April 2016 with comments of the European Banking Federation (EBF), the voice of European banks, on the proposal for anti-avoidance Directive published by the Commission on 28 January 2016 (hereinafter referred to as the “ATAD”). I am aware the Association for the Financial Markets in Europe (AFME) is sending you a very similar letter to draw your attention to the same concerns as ours.
The purpose of the present letter is to set out common concerns of our organizations regarding the ATAD. The general tenor of the present submission is that a premature implementation of the ATAD bears the risk of causing severe disruptions within the Internal Market and may create a significant competitive disadvantage vis-à-vis the EU’s major trading partners. We are particularly concerned by the lack of impact assessment regarding specific EU measures foreseen in the ATAD. We note that certain provisions remain at this stage very vague and would certainly need to be further refined in order to ensure consistency and legal certainty.
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