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Portugal Publishes Law to Implement ATAD Hybrid Mismatch Measures

16 July 2020

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Approved Changes

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Portugal

Portugal published Law 24/2020 in the Official Gazette on 6 July 2020, which provides for the implementation of the hybrid mismatch rules of the EU Anti-Tax Avoidance Directive and the Directive as amended (ATAD1 and ATAD2). This includes measures to counter hybrid mismatches resulting in double deduction and deduction without inclusion outcomes, which are generally dealt with by denying a deduction in determining taxable profit or requiring the inclusion of income. Specific measures are also provided to address reverse hybrid mismatches and residence mismatches. The hybrid mismatch measures are generally effective from 1 January 2020, although the measures for reverse...