Sandy Bhogal and Kitty Swanson (Mayer Brown) examine the EU’s new anti-hybrids directive.
Background to the Directive
On 12 July 2016 the EU formally adopted Directive 2016/1164 known as the Anti-Tax Avoidance Directive (ATAD) which included measures to implement the recommendations of a number of BEPS action items including Action 2 on hybrid mismatch arrangements. The hybrid mismatch provisions of the ATAD were limited in scope and only addressed mismatch arrangements arising between EU member states. It was therefore agreed that there should be a subsequent directive to amend the ATAD to address other areas of concern identified by Action 2 including introducing measures to address hybrid mismatch arrangements with third countries and expand the range of mismatches targeted. An initial draft was published on 25 October 2016 and the text of the Directive (ATAD II) was...
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Sandy Bhogal and Kitty Swanson (Mayer Brown) examine the EU’s new anti-hybrids directive.
Background to the Directive
On 12 July 2016 the EU formally adopted Directive 2016/1164 known as the Anti-Tax Avoidance Directive (ATAD) which included measures to implement the recommendations of a number of BEPS action items including Action 2 on hybrid mismatch arrangements. The hybrid mismatch provisions of the ATAD were limited in scope and only addressed mismatch arrangements arising between EU member states. It was therefore agreed that there should be a subsequent directive to amend the ATAD to address other areas of concern identified by Action 2 including introducing measures to address hybrid mismatch arrangements with third countries and expand the range of mismatches targeted. An initial draft was published on 25 October 2016 and the text of the Directive (ATAD II) was...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
