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Italy issues final guidance on hybrid mismatches

23 February 2022

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Tax Alerts, Legislation & Policy, Na...

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United States, Italy, European Union

Executive summaryThe Italian Tax Authorities issued Circular Letter n. 2/2022 on hybrid mismatch rules (the Circular) in January 2022. The 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 Circular follows a public consultation period (from October 2021 to 19 November 2021) during which stakeholders could provide comments on a previously circulated draft. Among some few differences with the document published for consultation, the Circular states that anti-hybrid rules may not apply to tax consequences of hybrid mismatch events that occurred (for calendar...