27 October 2016 European Commission releases draft directive addressing hybrid mismatches with non-EU countries The European Commission announced a new package of corporate tax reforms on October 25. The package includes three separate legislative initiatives. The current proposal on hybrid mismatches (ATAD 2) amending the Anti-Tax Avoidance Directive (ATAD) agreed in June is the Commission's response to the ECOFIN Council statement of June 20. In that statement, the ECOFIN Council requested the Commission to put forward by October 2016, a proposal on hybrid mismatches involving third countries in order to provide for rules consistent with and no less effective than the rules recommended by the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) report on Action 2, with a view to reaching an agreement by the end of 2016. A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details. Document ID: 2016-1821 |
