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By Oliver R. HOOR, Keith O’DONNELL and Samantha SCHMITZ-MERLE, Atoz *
On 21 February 2017, the EU Finance Ministers agreed during a meeting of the ECOFIN(1) on a compromise proposal for an EU Directive amending Directive (EU) 2016/1164 (the so-called Anti-Tax-Avoidance-Directive, “ATAD”). While the ATAD already included measures dealing with hybrid mismatches in an EU context, ATAD 2 replaces these rules and extends their scope to transactions involving third countries. The EU Council is expected to adopt ATAD 2 once the European Parliament has given its opinion. This article outlines the hybrid mismatches targeted by the directive, the mechanisms that should avoid mismatch outcomes and the areas where ATAD 2 should have no impact.
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