The Impact of the Transposition of the ATAD on the Greek Tax System - Intertax View The Impact of the Transposition of the ATAD on the Greek Tax System by Petros Pantazopoulos,Katerina Kalampaliki - Intertax The Impact of the Transposition of the ATAD on the Greek Tax System Petros Pantazopoulos Katerina Kalampaliki 48 2
response to the Anti-Tax Avoidance Directive (ATAD), Greece has recently amended its
legislation with L. 4607/2019 regarding interest deduction limitation rules,
controlled foreign company (CFC) rules, and the General Anti-Abuse Rule (GAAR).
In this article, the impact of the transposition of the ATAD in the
aforementioned three rules will be analysed. In addition, a comparative survey
between them and the respective provisions of the ATAD will occur in which it
will be examined to what extent the aforesaid anti-tax avoidance rules have
been changed by the transposition of the ATAD. Lastly, a critical analysis of
each of them will take place concerning the issues that may arise and on their compatibility
with ECJ case law.