ATAD Series Session 1: ATAD 1 – Interest Limitation Rule & Exit Tax
|This course aims to provide participants with a better understanding on the Anti-Tax Avoidance Rule I as set out by the EU Commission. The course shall provide an in-depth analysis of the Interest Limitation Rule which discourages artificial debt arrangements designed to minimise taxes as well as Exit Taxation which prevents companies from avoiding tax when re-locating assets.
Furthemore, a practical approach on how these Directives are present within the Malta Income Tax Return in their respective tax return attachments shall be provided.
ATAD Series Session 2: ATAD 1 – Controlled Foreign Company Rules and GAAR
This course shall delve into the Controlled Foreign Company Rules governed by the Anti-Tax Avoidance Rule I which aims at detering profit shifting to a low/no tax country. The scope of the session will grant participants a comprehensive insight on the applicability of these Rules and how such rules are present in the Malta Income Tax Return.
This course shall also provide an insight into the General Anti-Abuse Rule which counteracts aggressive tax planning when other rules do not apply.
ATAD Series Session 3: ATAD 2 – Hybrid mismatches – Identification & Analysis