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The EC has sent letters of formal notice - equivalent to bringing legal proceedings - to Cyprus, Hungary, the Netherlands, Portugal, Romania, Slovakia, Slovenia and Spain, all of whom Brussels says has yet to implement any of the Directive's elements.
In addition, the EC said Austria, Belgium, the Czech Republic, Estonia, Greece, Ireland, Luxembourg and Poland had only partially implemented the measures.
In a statement the EC said: "The Commission regrets that the Member States in question have failed to transpose the Directive in a timely manner and encourages them all to do so urgently, bearing in mind the importance of these rules for the EU's collective interest."
The EU also singled out Lexembourg for having "allowed firms unlimited deductibility of interest" from their tax bills.