On 28 December 2018, Estonia published the Income Tax Amendment Act of 12 December 2018 in the Official Gazette. The main measures of the Act provide for the implementation of the EU Anti-Tax Avoidance Directive (ATAD). The measures are summarized as follows: GAAR A new general anti-avoidance rule (GAAR) based on ATAD is introduced, which includes that an arrangement or a series of arrangements may be disregarded if put into place for the essential purpose of obtaining a tax advantage that defeats the object or purpose of the tax law or an international agreement, and not for valid commercial reasons...