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Finnish Parliament Considering Draft Bill for Reverse Hybrid Mismatch Rules

02 November 2021

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Proposed Changes

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Finland

The Finnish parliament is considering draft bill HE 204/2021 vp, which provides for the introduction of new hybrid mismatch rules. In particular, the draft includes measures to transpose the reverse hybrid mismatch rules as per Article 9(a) of the EU Anti-Tax Avoidance Directive as amended (ATAD2). The rules generally provide that where a tax transparent entity is at least 50% directly or indirectly owned by a legal entity partner together with related partners, the share of income from the transparent entity will be taxed in Finland if the state of residence of such partner does not tax the income because...