Bulgaria has published the Law Amending and Supplementing the Corporate Income Tax Act, which provides for the implementation of the reverse hybrid mismatch rules of the EU Anti-Tax Avoidance Directive as amended (ATAD2). This includes that where one or more foreign entities are affiliated undertakings and collectively hold directly or indirectly 50% or more of the voting rights, the share capital, or the right to profits of a hybrid entity incorporated or established in Bulgaria that is not considered a taxable person in Bulgaria but is considered a taxable person in the jurisdiction(s) of the foreign entity(s), then such hybrid...