Sweden: Parliament accepts Bill to implement EU ATAD reverse hybrid mismatches
On 16 March 2021, the Swedish Parliament (Riksdag) has accepted Bill No. 2020/21:111 to implement EU Anti-Tax Avoidance Directive (ATAD) reverse hybrid mismatches. In this bill, it is proposed that rules be introduced regarding the tax treatment
See MoreIreland: President signs the Finance Bill 2020 into Law
On 19 December 2020, the President signed the Finance Bill 2020 into Law, which underpins the Government’s support for the economy in the face of Covid-19 pandemic and the ongoing threat of a no-deal Brexit. The Finance Act 2020 provisions
See MoreAustralia: ATO clarifying the operation of hybrid mismatch rules
Australia's hybrid mismatch rules have been updated with a number of technical amendments in order to clarify and improve the rules' operation. In the 2019–20 Budget on 2 April 2019, the Australian government announced the measure Tax
See MoreGreece: Parliament published two Laws to introduce various changes in transfer pricing context
On 31 July 2020 and on 29 July 2020, the Greek Parliament Officially published two Laws, L. 4714/2020 and L. 4712/2020 respectively regarding various sections of transfer pricing. The two Laws cover the following changes: Tax dispute Resolution
See MoreFinland publishes guidance on hybrid mismatch rules
On 3 July 2020, the tax authorities have published guidance no. VH/2738/00.01.00/2020 concerning the legislation on cross-border hybrid mismatches, transposing the hybrid mismatch rules, the EU Anti-Tax Avoidance Directive (ATAD) 2016/1164 and
See MoreIreland: Irish Revenue introduces new hybrid mismatch guide
On 8 July 2020, the Revenue published eBrief No. 137/20 on a new Tax and Duty Manual Part 35C-00-01, which provides an overview of the anti-hybrid rules that were introduced into Part 35C TCA 1997 by Finance Act 2019. This manual covers following
See MoreAustralia: Integrity rule law companion ruling finalized
In April 2019, Australian Taxation Office (ATO) released a draft Law Companion Ruling on the Organization for Economic Cooperation and Development (OECD) hybrid mismatch rules related to integrity rule. The ATO have now released draft LCR
See MoreGreece: Finance Ministry published a Bill regarding anti-hybrid rules for public consultation
On 7 July 2020, the Ministry of Finance published a draft bill related to the transposition of anti-hybrid rules for public consultation. This Bill includes a new article, Article 50 to amend the Article 66B and covers to the extent in where a
See MoreCyprus Gazettes EU Anti-Tax Avoidance Directive
After the partial adoption of the EU Anti-Tax Avoidance Directive (ATAD I) of 12 July 2016 in 2019, on 19 June 2020 the Parliament of Cyprus voted into law the remaining provisions of ATAD I, as well as the provisions of the EU ATAD II of
See MoreCyprus: House of Representatives passed the law to implement EU ATAD
On 19 June 2020, the Cyprus Parliament adopted the law to implement the provisions EU Anti-Tax Avoidance Directive (ATAD I) with respect to exit taxation rules, as well as, the provisions of the amending Directive (ATAD II) with respect to
See MorePoland: Parliament passes a law implementing ATADII & DAC 6
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
See MoreAustralia: New proposals on Hybrid mismatch rule
On 13 May 2020, the Treasury Laws Amendment Bill 2020 was presented in the House of Representatives that would make technical changes to the hybrid mismatch rules addressing integrity of income tax laws and their application to multinational
See MoreUK: Public consultation on hybrid mismatches rule
On 19 March 2020, the tax authority the United Kingdom has issued a consultation document for public comments on the impact of the double deduction rules and the acting together rules within the hybrid and other mismatches regime at Part 6A of the
See MoreLatvia implements EU ATAD hybrid mismatch measures
On 11 February 2020, Latvia published the Law of 30 January 2020 on Amendments to the Corporate Income Tax Act in the official gazette. The law includes the provision for the implementation of the hybrid mismatch measures of the EU Anti-Tax
See MoreEstonia implements EU ATAD 2 from 1 January 2020
Estonia has implemented the EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2). ATAD 2 amends the EU Directive 2016/1164 which extends the scope of the Hybrid Mismatches Rules to a wider range of transactions and also to apply to transactions with
See MoreMalta amends EU ATAD Implementation Regulations
Recently, Malta has published Legal Notice No. 29 of 2020 in the Official Gazette amending Regulation 10 of the EU Anti-Tax Avoidance Directives (ATAD) Implementation Regulations. The Regulation states that the reverse hybrid rules will apply from
See MorePoland: Council of Ministers submit ATAD2 hybrid mismatch measures to parliament
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
See MorePortugal: Draft bill to implement ATAD1 and ATAD2
On 30 January 2020, a draft bill was presented to the Parliament for the execution of the hybrid mismatch rules of the EU Anti-Tax Avoidance Directive and the Directive as amended (ATAD1 and ATAD2). This consists of measures to counter hybrid
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