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17 January 2022. 1 min read. On December 22, 2021, the European Commission issued a proposal for a Directive aimed at fighting the use of shell entities and arrangements for tax purposes (the Directive). The proposal comes in the form of amendments to Council Directive 2016/1164/EU – the EU Anti-Tax Avoidance Directive …
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The Anti-Tax Avoidance Directive contains five legally-binding anti-abuse measures, which all Member States should apply against common forms of aggressive tax planning. Member States should apply these measures as from 1 January 2019. It creates a minimum level of protection against corporate tax avoidance throughout the EU, while …
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August 23, 2022. KPMG's EU Tax Centre released a report, based on a survey of KPMG member firms in the EU, on the implementation of the five measures included in the Anti-Tax Avoidance Directive (ATAD I) Council Directive (EU) 2016/1164 and the Anti-Tax Avoidance Directive (ATAD II) Council Directive (EU) 2017/952, into the …
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In this briefing, we examine the ECON Amendments to ATAD 3 approved by the European Parliament. The amendments impact: the scope of ATAD 3 – adjusting the thresholds imposed under the gateway tests and amending the carve-outs; the reporting requirements – modifying the minimum substance indicators and documentary evidence …
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Email. On 21 June, the Economic and Financial Affairs Council (ECOFIN) reached a consensus on the "Anti-Tax Avoidance Directive" (ATAD). Some of the measures of this Directive directly affect groups' existing financing set-ups. The main impact is the implementation of BEPS Action 4 via a Directive, which will impose a general interest ...
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Autothermal thermophilic aerobic digestion (ATAD) is a microbial fermentation process characterized as a tertiary treatment of waste material carried out in jacketed reactors. The process can be carried out on a variety of waste sludge ranging from human, animal, food, or pharmaceutical waste where …
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ATAD1 (FLJ14600, Msp1) protein expression summary. Outer mitochondrial translocase required to remove mislocalized tail-anchored transmembrane proteins on mitochondria 1.Specifically recognizes and binds tail-anchored transmembrane proteins: acts as a dislocase that mediates the ATP-dependent extraction of mistargeted tail-anchored …
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ATAD2. The anti-hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD 2) aim to prevent situations of a double deduction and a deduction without a corresponding inclusion of the income at the level of the recipient resulting from a hybrid mismatch. All EU Member States have implemented ATAD2 in their domestic laws as from 1 January ...
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Fig. 1 displays the conceptual diagrams of ATAD, composting, activated sludge, and methane fermentation. ATAD is called liquid composting because the total solids (TS) content in feedstock typically ranges from 1% to 6%. ATAD is rarely used to treat organic waste with a TS content exceeding 6% owing to the increased viscosity, making …
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The EU Commission's proposal for a council directive (the "Directive") laying down rules to circumvent the misuse of so-called "shell entities" was released on 22 December 2021 (the "Proposal"). The Proposal is expected to be adopted in the first quarter of 2022. The aim is that Member States transpose the Directive into domestic law by 30 June 2023, with the …
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Whilst the second phase of ATAD2 regarding the reverse hybrid mismatches will just begin to be applied from 1 January 2022 in Luxembourg, the EU Commission launched a public consultation on the use of shelf companies, which should lead to a legislative proposal by the end of this year (ATAD3). In addition, although the …
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On 22 December 2021, the European Commission published one of its most ambitious and far-reaching draft directives known as the ATAD III directive. This proposal aims to tackle the misuse of entities with limited substance that are interposed in group structures to benefit from EU-reliefs on interests, royalties, and dividends streams.
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As of the end of day on the, the price of an TATNEFT PJSC Sponsored ADR (ATAD.L) share was $4.50. What is the 52-week high and low for TATNEFT PJSC Sponsored ADR Fund? The 52-week high for TATNEFT PJSC Sponsored ADR Fund is $4.50 and the 52-week low is $2.35.
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Patricia Gudino Jonas and Zeeshan Ahmed from EY Luxembourg share their views. The ATAD 3 Directive was proposed by the European Commission in December 2021 with the purpose of preventing the misuse of "shell" entities. It targets EU entities with cross-border "relevant income" (broadly passive income) with outsourced administration …
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Autothermal thermophilic aerobic digestion (ATAD) has been used to stabilize organic waste since the 1960s and is considered sustainable technology. ATAD has several advantages, including high biodegradation efficiency, pathogen inactivation, and ease of operation. Although ATAD research has a long …
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ATAD 3 Shell Companies. The definition of the widespread term 'shell', often interchangeably with terms such as 'letterbox', 'mailbox', 'special purpose entity', special purpose vehicle' and similar, is defined differently in different contexts. For the purpose of ATAD 3, shell companies refer to three types of shell companies:
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WHO WE ARE. ATAD Steel Structure Corporation is the leading Steel Structure Company in Southeast Asia. ATAD specializes in providing complete solutions including: Design, Fabrication and Erection of high-quality steel structure products. With a well-trained workforce of over 2200 employees and two advanced factories, we have constructed …
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ATAD2 protein is an emerging oncogene that has strongly been linked to the etiology of multiple advanced human cancers. Therapeutically, despite the fact that genetic suppression/knockdown studies have validated it as a compelling drug target for future therapeutic development, recent druggability assessment data suggest that direct …
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Alerta Tributario España. El 10 de marzo de 2021 se ha publicado el Real Decreto-ley 4/2021, de 9 de marzo, que traspone la Directiva (UE) 2016/1164 del Consejo, de 12 de julio de 2016, modificada por la Directiva (UE) 2017/952 del Consejo, de 29 de mayo de 2017 (Directiva ATAD 2), en relación con las "asimetrías híbridas", …
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Domestic tax base erosion and profit shifting (BEPS) due to multinational enterprises exploiting gaps and mismatches between different countries' tax systems affects all countries. Developing countries' higher reliance on corporate income tax means they suffer from BEPS disproportionately. Business operates internationally, so governments must …
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This study details a unique process of autothermal thermophilic aerobic digestion (ATAD) of human excreta useful in producing nitrogen-rich and pathogen-free organic fertilizer. The process was divided into initial, middle, and final phases, based on changes in temperature, dissolved oxygen (DO), and bacterial community structure.
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The ATAD3 Directive introduces substance requirements for certain tax resident companies of the EU, where not meeting these substance requirements could result in an exposure to (additional) taxation. In this update we provide you with the key features of the ATAD3 Directive. 1. Background, Object and Purpose.
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Make an enquiry. New European Commission proposals seek to crack down on the misuse of shell companies. Antonello Argenziano, Product Director, Daan van Leeuwen, Senior Tax Counsel, and Brecht Guldemont, Senior Business Development Director, explain the impact of ATAD 3 and how to get ready for it.. The European Union …
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