Hybrid mismatch arrangements, ATAD II

Published: 06 June 2017


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The EU has taken a further step to address particular forms of corporate tax avoidance, adopting rules to close down 'hybrid mismatches' with the tax systems of third countries.

On 29 May 2017, the Council adopted a directive to prevent corporate groups from exploiting the disparities between two or more tax jurisdictions to reduce their overall tax liability (here).

The directive is one of a package of corporate taxation proposals presented by the Commission in October 2016. Agreement was reached at a meeting of the Economic and Financial Affairs Council. Member states will have until 31 December 2019 to transpose the directive into national laws and regulation.

For further information, please contact Paul HaleEnrique Clemente