The UK’s emerging response to the EU’s ATAD

The EU’s Anti-Tax Avoidance Directive is intended to apply minimum standards of anti-avoidance legislation across the EU, with the first elements to be reflected in member states’ domestic law by 31 December 2018. The UK will be required to conform with the directive until it departs the EU (and potentially afterwards, depending upon the final Withdrawal Agreement); as a result, changes are proposed to the UK legislation in respect of controlled foreign companies (from 1 January 2019), hybrid mismatches and exit taxation (from 1 January 2020).