EU Anti-Tax Avoidance Directive 2: hybrid mismatches with third countries
On February 21, 2017 the EU Member States reached agreement on a Directive that will amend the Anti-Tax Avoidance Directive (Council Directive (EU) 2016/1164 of July 12, 2016, ’ATAD 1’). The new Directive (‘ATAD 2’) amends Article 9 of ATAD 1, which covered certain hybrid mismatches between EU Member States.