Executive summaryOn 30 November 2020, the Spanish Ministry of Finance released a draft Bill to implement the European Union (EU) Anti-Tax Avoidance Directive (Council Directive 2017/952 of 29 May 2017, “EU ATAD 2”) into the Spanish Corporate Income Tax (CIT) and Nonresident Income Tax (NRIT) provisions. This draft Bill is now subject to public consultation until 23 December 2020.Detailed discussionThe EU ATAD 2 requires EU Member States to include a number of anti-hybrid provisions in line with the OECD1 BEPS2 Action 2 in their domestic legislation.The draft rules published by the Spanish Ministry of Finance are generally in line with the EU ATAD 2 provisions and...