Estonia has implemented the hybrid mismatch rules of the EU Anti-Tax Avoidance Directive as amended (ATAD2). This includes rules that apply from 1 January 2020 to address double deduction and deduction non-inclusion mismatch outcomes between associated companies, a legal person and its permanent establishment, between two permanent establishments of the same entity, or in the framework of a structured arrangement and certain other cases. Rules to address reverse hybrid mismatches apply from 1 January 2022. In general, a hybrid mismatch is addressed by either denying a deduction (taxing a deductible expense) or requiring an inclusion of income. In the event...