Legal briefing

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


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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