On 26 January 2022, the Italian Revenue Agency (IRA) has declared the finalization of Circular No. 2/2022. The circular clarifies the hybrid mismatch rules that has introduced as part of the Decree No. 142 of 2018, which transposed the measures of the EU Anti-Tax Avoidance Directive (ATAD).
It includes the hybrid mismatch rules of the ATAD as amended (ATAD2) to incorporate double deduction as well as deduction without inclusion mismatches. Generally, these rules apply from 1 January 2020, while the reverse hybrid rules apply from 1 January 2022.
