On 5 February 2020, Poland’s Council of Ministers submitted some tax measures in parliament including the hybrid mismatch measures of the EU Anti-Tax Avoidance Directive as amended (ATAD2).
ATAD2 would address tax avoidance through hybrid mismatches in related relationships. Hybrid mismatches refer to situations when differences between tax systems are used with regard to the qualification of entities, instruments or permanent establishments. The main purpose of implementing the anti-hybrid measures is to counter the situation of double tax deductions or tax deductions of expenses without recognition the corresponding income.