General anti-abuse rule for corporate income tax

Article 108 of the 2019 Finance Act creates Article 205 A of the General Tax Code, transposing Article 6 of Directive (EU) 2016/1164 (ATAD): for corporate income tax purposes, the tax authority disregards any arrangement or series of arrangements put in place with the main purpose, or one of the main purposes, of obtaining a tax advantage that defeats the object or purpose of the applicable tax law and that is not genuine. A specific advance ruling procedure is created (Art. L. 80 B, 9° bis of the Tax Procedure Code). Applicable to financial years beginning on or after 1 January 2019.