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Czech Senate Passes Amendment Concerning Hybrid Mismatches under the Parent-Subsidiary Directive

19 April 2016

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Approved Changes

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Czech Rep

The Czech Senate (upper house of parliament) has reportedly passed legislation implementing the amendment to the EU Parent-Subsidiary Directive concerning hybrid mismatch arrangements. Under the new rule, the participation exemption provided for dividends will be denied if a dividend received is tax deductible for the distributing subsidiary in its country of residence. The legislation has already been passed by the Chamber of Deputies (lower house), and must now be signed by the president and published in the Official Gazette before entering into force. Once in force, it will apply from the first day of the following month.