Italy Finalizes Circular Providing Guidance on Hybrid Mismatch Rules

The Italian Revenue Agency (IRA) has announced the finalization of Circular No. 2/E of 26 January 2022. The circular concerns the hybrid mismatch rules introduced as part of Decree No. 142 of 2018, which transposed the measures of the EU Anti-Tax Avoidance Directive (ATAD). This includes the hybrid mismatch rules of the ATAD as amended (ATAD2) to address double deduction and deduction without…
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