The Spanish Council of Ministers has approved an RDL through which the reverse hybrid mismatch rules under the European Union (EU) ATAD 2 will be implemented.These rules were published on 19 October 2022 and are effective as from 1 January 2022.Where the relevant requirements are met, the Spanish reverse hybrid entity will become a Spanish Corporate Income Tax taxpayer.Executive summary On 18 October 2022, the Spanish Council of Ministers approved the Royal-Decree Law (RDL) implementing the reverse hybrid rules set forth in the EU Anti-Tax Avoidance Directive (Council Directive 2017/952 of 29 May 2017, “EU ATAD 2”) into the Spanish...