Singapore: IRAS revises e-tax guide on hybrid instrument taxation
The Inland Revenue Authority of Singapore (IRAS) has released the third edition of its e-Tax Guide on the Income Tax Treatment of Hybrid Instruments on 26 December 2025. The guide outlines how hybrid instruments are classified as debt or equity
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Ireland: Irish Revenue updates guidance on anti-hybrid rules for partnerships
The Irish Revenue has issued eBrief No. 223/25, on 27 November 2025, on the country’s anti-hybrid rules, reflecting changes to the application of the associated enterprises test for partnerships. Tax and Duty Manual Part 35C-00-01 has been
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South Africa: National Treasury withdraws amendment on hybrid equity instruments
National Treasury has retracted its proposal to amend the definition of “hybrid equity instrument” in section 8E of the Income Tax Act following industry concerns. South Africa's National Treasury confirmed that the proposal in the 2025 draft
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South Africa: Treasury proposes strengthening anti-avoidance rules for hybrid equity instruments
South Africa proposes more rigid tax rules on hybrid equity instruments, expanding the scope and taxing dividends as income from 1 January 2026. The South African National Treasury has proposed changes to section 8E of the Income Tax Act to
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Italy implements emergency tax revisions on CFC, hybrid mismatch penalty rules
Urgent tax measures include revising the domestic CFC rules, tax loss carry-forward provisions, and the penalty protection regime for hybrid mismatch assessments. Italy’s parliament converted Law Decree No. 84 of 17 June 2025 into law with
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Italy extends deadline for penalty protection on hybrid mismatch documentation
Calendar-year taxpayers now have until 31 October 2025 to finalise documentation for the years 2020 through 2024. Italy’s Ministry of Economy and Finance has issued Decree Law No. 84 on 17 June 2025, extending the deadline for taxpayers to
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Italy announces penalty relief rules for hybrid mismatch rules
Italy's Ministry of Economy and Finance has published the Decree of 6 December 2024 outlining the penalty reliefs rules for violations of Italy's hybrid mismatch rules. The Decree’s penalty relief rules are taken from Legislative Decree No. 209
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Australia: ATO finalises hybrid mismatch taxation rules
The Australian Taxation Office (ATO) released Taxation Determination (TD) 2024/4 - Income tax: hybrid mismatch rules - application of certain aspects of the 'liable entity' and 'hybrid payer' definitions on 3 July, 2024. TD 2024/4 is applicable
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Australia: ATO initiates consultation on draft tax determination for hybrid mismatch rules
The Australian Taxation Office (ATO) released the draft Taxation Determination (TD) 2024/D1 - Income tax: hybrid mismatch rules - application of certain aspects of the 'liable entity' and 'hybrid payer' definitions. This draft Determination
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Australia: ATO issues guidance on hybrid mismatch rules
On 30 January 2024, the Australian Taxation Office (ATO) published guidance on the hybrid mismatch rules. The guidance explains why hybrid mismatch rules exist, how hybrid mismatch rules work and when they should be applied. Australia's hybrid
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Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
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Germany released new draft guidance on anti-hybrid rules
On 14 July 2023, the German Ministry of Finance has released a draft decree outlining the application of the country's anti-hybrid rules, established in 2021 under the European Union (EU) Anti-Tax Avoidance Directive (ATAD) implementation Law. These
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Lithuania updates definition of reverse hybrid entities to comply with ATAD2
Lithuania has amended its definition of a "reverse hybrid entity" to comply with the EU Anti-Tax Avoidance Directive (ATAD2). Previously, a Lithuanian entity was considered a reverse hybrid if it was owned by a tax resident of a foreign country, and
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Luxembourg: Tax Authority publishes guidance on reverse hybrid rules
On 9 June 2023, the Luxembourg Tax Authority published Circular L.I.R. n° 168quater providing guidance on reverse hybrid mismatch regulations. The Circular aims to provide further clarity on various aspects, including the tax classification of
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Luxembourg: Parliament approves budget law 2023
On 15 December 2022, the Luxembourg Parliament approved the budget law 2023. There is no major tax reform or an increase in the tax rate in the draft budget law. Most of the measures will apply from 1 January 2023. The budget law sets out the
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Spain: Council of Ministers adopts Royal-Decree implementing the reverse hybrid rules
On 18 October 2022, the Spanish Council of Ministers approved the Royal Decree-Law (RDL) implementing the reverse hybrid rules under the Anti-Tax Avoidance Directive 2017/952 (ATAD-2). The law generally aims to combat tax avoidance as a result of a
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Luxembourg: Finance Minister presents draft budget law 2023 to the Parliament
On 12 October 2020, Luxembourg’s Finance Minister presented the draft budget law 2023 to the Parliament. There are no measures regarding major tax reform or an increase in the tax rate in the draft budget law. The draft budget law sets out the
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Ireland: Revenue issues eBrief on anti-hybrid rules guidance
On 29 June 2022, the Irish Revenue published an eBrief No. 137/22 to announce a manual to update the guidance on anti-hybrid rules. Accordingly, Tax and Duty Manual Part 35C-00-01 - Guidance on the Anti-hybrid rules - has been updated for
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