CFC Rules and Anti-Tax Avoidance Directive - EC Tax Review View CFC Rules and Anti-Tax Avoidance Directive by - EC Tax Review CFC Rules and Anti-Tax Avoidance Directive 26 3

The effects of the Anti-Tax Avoidance Directive (ATAD) on Controlled Foreign Company (CFC) rules have been instructively discussed in depth, especially in the German scholarly literature.1 The following contribution re-examines a few aspects against the background of a hypothetical case and addresses various issues, including the question as to whether the Directive does not also give taxpayers a certain minimum level of protection and at the same time impose general limits on national legislatures.  

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