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Investor Presentaiton

ATAD-Implementation Bill 反避税指令 (ATAD)实施法案 母 AA • • • • • ATAD = EU Anti Tax Avoidance Directive (Council Directive (EU) 2016/1164 of 12 July 2016; Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164). The ATAD rules had to be implemented into domestic law by 31 December 2018 and 31 December 2019. Measures of the ATAD include controlled foreign company rules (CFC), hybrid-mismatch rules, exit taxation rules, interest limitation and general anti-abuse rules. The ATAD-Implementation Draft Bill forsees also changes to the German Transfer Pricing Rules. So far no political consensus was reached to push this Bill forward. _ 10 December 2019 Issue of first draft of the ATAD- Implementation Bill _ 24 March 2020 Issue of the second draft of the ATAD-Implementation Bill 17 November 2020 Leaking of unofficial revision of the ATAD-Implementation Bill Today _ Still not in the legislative process © 2021. For information, contact Deloitte China. 17
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