INREV Response to Commission Call for Evidence on the evaluation of Anti-tax Avoidance Directive (ATAD I)

INREV response to the European Commissions Call for evidence on the evaluation of Anti-tax Avoidance Directive (ATAD). INREV calls for improvements to GAAR to address concerns, including the misuse of shell entities rather than adopting the proposed Unshell Directive. We urge that any changes be proportional to the benefits and consider the costs involved. INREV also highlights the need to account for the unique characteristics of the EU real estate investment markets when making adjustments to ATAD.