The Council adopted the anti-tax avoidance directive
("ATAD", Council Directive (EU) 2016/1164) in 2016. The
directive establishes a number of legally binding measures against
aggressive tax planning. In particular, it aims to address
situations where corporate groups take advantage of disparities
between national tax systems in order to reduce their overall tax
liability. For this purpose, the directive provides for legal
provisions against aggressive tax planning relating to, in
particular, interest limitation, exit taxation rules, controlled
foreign company rules, general anti-abuse rules or rules on hybrid
mismatches. The directive contains several significant
modifications as compared to earlier practice, including the
interest limitation rule, that may affect the functioning of
Hungarian companies, and likewise, new entitlements for relief may
be adopted. In respect of the interest limitation rule, according
to the provisions of the directive, exceeding borrowing
