Executive summary
The Italian Tax Authorities launched a public consultation in October 2021 on a draft circular regarding the hybrid mismatch rules (Draft Circular). The Draft Circular provides interpretations and examples on the provisions governed by Decree 142/2018 which implemented the European Union (EU) Anti-Tax Avoidance Directive (ATAD) in domestic law. The consultation period ended on 19 November 2021 and a final circular is now expected to be issued.
This Alert summarizes the key topic…