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On 25 June 2021, the German Federal Council (Bundesrat) approved the Act on the Implementation of the Anti-Tax Avoidance Directive, which had already been published in the Federal Law Gazette (Bundesgesetzblatt) on 30 June 2021.
The purpose of the Act on the Implementation of the Anti-Tax Avoidance Directive is, in particular, to transpose the EU ATAD Directive (Anti-Tax Avoidance Directive 2016/1164 amended by Directive 2017/952 of 29 May 2017) into German tax law and to adapt the German Foreign Tax Act (Außensteuergesetz, AStG) or the so-called controlled foreign corporation rules associated with it.
With effect from1 January 2020, the EU ATAD Directive requires member states to introduce rules to combat international tax avoidance or to align their...
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