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Italy issues draft guidance on hybrid mismatches

23 November 2021

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Tax Alerts, Legislation & Policy, Na...

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Italy, European Union

Executive summaryThe Italian Tax Authorities launched a public consultation in October 2021 on a draft circular regarding the hybrid mismatch rules (Draft Circular). The Draft Circular provides interpretations and examples on the provisions governed by Decree 142/2018 which implemented the European Union (EU) Anti-Tax Avoidance Directive (ATAD) in domestic law. The consultation period ended on 19 November 2021 and a final circular is now expected to be issued. This Alert summarizes the key topics addressed by the Draft Circular.Detailed discussionRelevance of the Organisation for Economic Co-operation and Development (OECD) Base Erosion Profit Shifting (BEPS) Action 2 reportsPrinciples and examples included...