Opinion Statement CFE 2/2025 on Technical Simplification of the EU Anti-Tax Avoidance Directive (ATAD)

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 It argues the interest limitation rule (ILR) is fragmented and outdated, proposing mandatory unlimited carry-forward, carve-outs for third-party debt and infrastructure and a higher EUR 3 million threshold.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.