ATAD, in

BEPS Action 2

Circular cases

Credit for foreign tax

Credit for underlying tax

Exemption of foreign income or profit


Permanent establishment and domestic attribution

Hybrid mismatches

Matching foreign income and tax with UK liability


Parent-Subsidiary Directive

Payment of foreign tax


Same income, different person

Source rules

Tax sparing

Transparent entities

Treaty restrictions on credit

Treaty versus unilateral relief