Critical Review of the ATAD Implementation: Foreword: The Implementation of the ATAD in the EU: The Same but not the Same

Unlike other previous EU Directives in the field of direct taxation, the Anti-Tax Avoidance Directive (ATAD)
Directives (1  and 2) have resulted in detailed legislation that countries are required to transpose into their own
domestic tax legislation. For this, countries have reviewed the compatibility of existing rules with the provisions of
the ATAD and, in accordance with this review, countries have introduced new rules, amended their existing rules,
or argued that the existing rules comply with the ATAD provisions.Against this background, this article provides a critical analysis of the implementation of the ATAD Directives by using the theory of legal transplants.