04
Nov
Last week, the EU Commission proposed to extend the scope of the EU hybrid mismatch rules by way of an amendment to the EU Anti Tax Avoidance Directive (the "ATAD"; see our Tax Alert of 23 June 2016 for further background. Under the proposed amendments to the EU hybrid mismatch rules, in contrast to the current scope, they will also apply to hybrid mismatches with third countries. Furthermore, the rules will apply to inter alia permanent establishment mismatches, dual resident mismatches...