Germany Consults on Draft Guidance for Hybrid Mismatch Rules
The German Ministry of Finance has published a draft BMF letter (guidance letter) regarding the application of the hybrid mismatch rules introduced by the Law for the implementation of the Anti-Tax Avoidance Directive (ATAD Implementation Act) in 2021. As previously reported, the rules are meant to eliminate differential tax treatment in connection with hybrid mismatches by preventing companie…
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