On 18 June 2020, the higher chamber of the parliament passed a bill implementing the rules related to hybrid mismatches with third countries (ATAD II) and completing the transposition of the DAC 6 rules in its domestic legislation.
Under the hybrid mismatches rules, taxpayers will not be entitled to include in the tax-deductible costs a payment resulting in double deduction (same deduction in two jurisdictions) or deduction with no inclusion (deduction of the income in one jurisdiction without inclusion in the tax base of the other).
The provisions implementing ATAD II will apply from 1 January 2021.
