Czech Parliament Considering Draft Law for Introduction of ATAD Measures

The Czech Parliament is currently considering a draft law for the introduction of measures to comply with the EU Anti-Tax Avoidance Directive. The measures include:

• The introduction of a general 30% of EBITDA interest deduction restriction with a CZK 80 million (~EUR 3 million) safe harbor limit with respect to both related and unrelated debt, with the current thin capitalization rules to be maintained (4:1 debt-equity ratio, 6:1 for banks and insurance companies);
• The introduction of CFC ru…