This opinion statement urges changes in the EU Anti-Tax Avoidance Directive, promoting better uniformity and clarity across Member States.
This opinion statement, submitted to the EU institutions in November 2025, comments on the Commission’s initiative to simplify the EU Anti-Tax Avoidance Directive (2016/1164). CFE supports “tax decluttering” and urges Member States to deliver real uniformity in implementation. It argues the interest limitation rule (ILR) is fragmented and outdated, proposing mandatory unlimited carry-forward, carve-outs for third-party debt and infrastructure and a higher EUR 3 million threshold. CFE also supports a de jure SME carve-out and targeted changes to CFC, hybrid mismatch and GAAR rules.
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CFE Tax Advisers Europe (2026) studied this question.
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