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 non-EU countries.

It includes rules for hybrid permanent establishment mismatches, hybrid transfers, imported mismatches, and dual resident mismatches. ATAD 2 is effective from 1 January 2020 in Estonia, except for the reverse hybrid rules which will apply only as of the tax year 2022.