Coinciding with the CCCTB relaunch on 25 October, the Commission issued draft legislation to cover Transfer Pricing Dispute Resolution and the tax treatment of so-called Hybrid Instruments.

The latter takes the form of an amendment to the existing Anti-Tax Avoidance Directive, which seeks to limit the deductibility of interest, impose exit taxes on changes of tax residence, apply CFC rules and ensure that a general anti-avoidance rule operates in all EU Member States. In essence both of these directives look to transpose into EU law ideas which have already featured in the OECD attempts to eliminate Base Erosion and Profit shifting (BEPS). As with all EU Direct Tax Directives, the unanimous approval of the 28 EU Member States is required before they can become law.