Publication date: 21 April 2016
Subject: Proposed Anti-Tax Avoidance Directive
I am writing to you as Chief Executive of the European Banking Federation (EBF), which is the voice of European banks.
The EBF is supportive of the development of new standards in the field of taxation and of the adoption of tax measures, including anti-avoidance measures, which are designed to foster fairer tax competition between jurisdictions globally and to simplify the international tax system with a view to preventing double taxation and double non-taxation.
Banks are already undergoing extensive adaptations of their standards, processes and systems to comply with an array of international and domestic regulatory changes, which aim to increase transparency and responsibility. A coordinated and coherent implementation of the OECD’s recommendations regarding base erosion and profit shifting (BEPS) at EU level, which would enhance a single uniform market, is another initiative that the EBF would support. For the reasons explained in the attached paper, the EBF, however, very much doubts that the proposed Anti-Tax Avoidance Directive (ATAD) released by the Commission could achieve this goal in the current stand of the drafting.