AmCham EU welcomes attempts to ensure that adoption of the OECD’s recommendations is consistent across the EU and with international trading partners where they are required in order to address identified issues by the OECD such as cross border hybridity, excessive interest deductibility and abusive transactions. Consistency is vital to minimise the negative impact on cross border trade and investment and to avoiding potential double taxation. However, we are concerned that the proposed measures are not appropriately drawn to tackle the identified issues without negative impact on the single market. For example, some measures may not be legally valid within the EU, some (when considered practically) will be administratively burdensome and arbitrary, and all either address issues that were not agreed to be minimum standards by the G20 and OECD, or differ from the OECD agreed best practices. The result is that the proposal goes far beyond the measures required to address the identified issues and will place EU businesses at a competitive disadvantage and discourage investment in the EU. 

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