The Dutch government has launched a public consultation on a proposal to implement the measures of the Anti-Tax Avoidance Directive (EU) 2016/1164 (ATAD1) into domestic law. The Directive includes anti-avoidance rules in five areas, including interest limitation rules, exit taxation rules, a general anti-abuse rule (GAAR), controlled foreign company (CFC) rules, and hybrid mismatch rules. With regard to each, the proposal includes the following: Interest Limitation Rules A 30% of EBITDA net interest expense deduction limitation is proposed with a EUR 3 million safe harbor and an exemption for companies that are not a member of a group. Excess interest...