Legal briefing

Analysis of the preliminary draft law on hybrid mismatches incorporating ATAD II

18/12/2020

This legal briefing analyses the text under consideration, which includes amendments to the Corporate Income Tax Law and the consolidated text of the Non-Resident´s Income Tax Law.

The Spanish Ministry of Finance has taken the first steps towards the transposition of the European Union (EU) Anti-Tax Avoidance Directive (Council Directive 2017/952 (EU) of 29 May 2017 (ATAD II) amending Directive 2016/1164 regarding hybrid mismatches with third countries (ATAD II), through the opening of a public hearing.

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