ATAD definition
Examples of ATAD in a sentence
As part of its anti-tax avoidance package the European Commission published a draft Anti-Tax Avoidance Directive on 28 January 2016, which was formally adopted by the Council of the European Union (the "Council") on 12 July 2016 in Council Directive (EU) 2016/1164 (the "ATAD").
On 21 February 2017, the Economic and Financial Affairs Council of the European Union agreed an amendment to the ATAD to provide for minimum standards for counteracting hybrid mismatches involving Member States and third countries ("ATAD 2").
ATAD 2 requires Member States to either delay deduction of payments, expenses or losses or include payments as taxable income, in case of hybrid mismatches.
Amongst the measures contained in the ATAD is an interest deductibility limitation rule similar to the recommendation contained in the Base Erosion and Profit Shifting project Action 4 proposals.
To assist in safety, all ATAD students must have adult supervision for overnight stays.
As a Teen-Age Diplomat, I accept responsibility to fulfill the purpose of the ATAD program to the best of my ability, and to abide by all policies and procedures set forth in this agreement.
Accordingly, as the Issuers will generally fund interest payments they make under the Securities from interest payments to which they are entitled under the Securities (that is such that the Issuers pay limited or no net interest), the restriction may be of limited relevance to the Issuers even if the ATAD were implemented as originally published.
Without derogating from the generality of the aforesaid, ATAD and BHP undertake that ATAD will transfer the Shares to BHP and complete the transfer prior to the Closing Date, in order to enable their transfer by BHP to the PURCHASERS in accordance with the provisions of the Shares Transfer Agreement.
Without derogating from the generality of the aforesaid, ATAD and BHP undertake that BHP will be the record owner and holder of the Shares and ATAD's rights thereunder and that ATAD will transfer the Shares to BHP, the Shares and ATAD's rights therein being free and clear of any Third Party Right whatsoever and complete the transfer prior to the Determining Date, in order to enable their transfer by BHP to the PURCHASERS as provided hereunder.
There is also a carve out in the ATAD for financial undertakings, although as currently drafted the Issuers would not be treated as financial undertakings.