In 2018, Austria did not adopt the regulations of the interest limitation rule under the European Union (EU) Anti-Tax Avoidance Directive1 (ATAD) into national law by 31 December, as required by the Directive. The Austrian Government believed that the domestic regulations of Section 12/1/9 of the Corporate Income Tax Act (CITA) (non-deductibility of interest paid on debt to refinance the acquisition of shares from affiliates) and Section 12/1/10 CITA (non-deductibility of interest and royalty payments to low-taxed affiliated companies) constituted equally effective rules as provided for under the ATAD.However, the European Commission subsequently found that Austria still must implement the interest limitation rule....