The European finance ministers have reached a political agreement on the second version of the anti-tax avoidance directive (ATAD2) specifically aiming to respond to hybrid mismatch situations between a member state and a third country (see EUROPE 11654).
These mismatches play on the difference in legal description of the same operation that may exist between one member state and another and give rise to situations of double non-taxation. The first version of the directive, which was the...