The Dutch Ministry of Finance has announced the launch of a public consultation on the implementation of the hybrid mismatch measures of the EU Anti-Tax Avoidance Directive as amended (ATAD2). The announcement notes in particular, the well-known Dutch CV / BV structure, which has allowed U.S. companies to defer taxation due to the differing Dutch and U.S. treatment of the structure. With the implementation of the ATAD2 measures, the attractiveness of the structure will be eliminated because the Netherlands will levy taxes if another country, such as the U.S. with the CV / BV structure, fails to levy taxes. The...