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Draft Bills for ATAD Hybrid Mismatch and DAC6 Rules Submitted in Finnish Parliament

05 November 2019

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Proposed Changes

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Finland

On 31 October 2019, the Finnish Government submitted draft bills in parliament to implement the hybrid mismatch rules of Council Directive (EU) 2016/1164, the Anti-Tax Avoidance Directive, as amended by Council Directive (EU) 2017/952 (ATAD2) and the reporting requirements for cross-border tax planning arrangements as required by Council Directive (EU) 2018/822 of 25 May 2018 (DAC6). Bill HE 68/2019 vp provides for the implementation of the hybrid mismatch rules through the amendment of the income tax regimes for corporations and partnerships and the rules on foreign tax credits in order to address double deduction mismatches, deduction without inclusion mismatches, mismatches...