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Germany released new draft guidance on anti-hybrid rules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
See MoreGreece enacts ATAD’s reverse hybrid rule
On 30 June 2022, the government of Greece enacted legislation implementing ATAD's reverse hybrid rule with retroactive effect from 1 January 2022. The rule does not apply to collective investment vehicles. The new rule applies to situations where
See MoreCanada: Government invites feedbacks on draft legislation regarding hybrid mismatches
On 29 April 2022, the Finance Department published a draft legislation proposals that would address hybrid mismatch arrangements, which are used primarily by multinational enterprises to avoid paying their fair share of tax, as committed to in
See MoreSpain adopts ATAD2 anti-hybrid rules
On 9 March 2022, Spanish government amended the Corporate Income Tax (CIT) law and the Non-Resident Income Tax (NRIT) law to address hybrid mismatches. The purpose of these amendments is to enact into Spanish domestic law the anti-hybrid rules
See MoreItaly: Final guidance on hybrid mismatches rules
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
See MoreBulgaria approves amendments to the CIT Act
On 20 January 2022, the Bulgarian Parliament passed the draft law amending and supplementing the Corporate Income Tax Act (CITA). The draft law provides for the implementation of the reverse hybrid mismatch rules of the EU Anti-Tax Avoidance
See MoreLithuania adopts important tax law changes
On 7 December 2021, the Lithuanian Parliament adopted several important amendments to the Law (No.IX-675) on the Corporate Income Tax of the Republic of Lithuania. The law proposed the following measures: Effective from 1 July 2022, the
See MoreIreland: President signs Finance Bill 2021 into Law
On 21 December 2021, President signed the 2021 Finance Bill into Finance Act 2021, which provides for the implementation of the 2022 Budget measures as well as some necessary anti-avoidance measures and technical changes to the tax code. Some of
See MoreFrance: Tax Authority publishes a guide regarding the application of anti-hybrid rules
On 15 December 2021, the Tax Authority published a guide, which covers the measures implemented in compliance with the EU Anti-Tax Avoidance Directive as amended (ATAD1 and ATAD2) as part of the Finance Law for 2020. The hybrid mismatch measures
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