From 1 January 2021, Polish regulations implementing the European Union (EU) Anti-Tax Avoidance Directive – ATAD 21 will enter into force. The purpose of the regulations is to prevent the exploitation of hybrid mismatches. Specifically, the regulations provide for non-deductibility of payments giving rise to a:Double deduction – where the same payment is deductible from the tax base in more than one jurisdictionDeduction without inclusion – if the payment is deducted from the tax base in Poland:with no matching inclusion of the payment in the taxpayer’s tax base in another jurisdiction, orwhere the payment qualifies for a tax relief in the...