Malta Publishes Regulations to Implement ATAD Hybrid Mismatch Rules

Malta has published Legal Notice 348 of 2019, which contains the European Union Anti-Tax Avoidance Directives Implementation (Amendment) Regulations, 2019. The Regulations generally apply from 1 January 2020 and provide for the implementation of the ATAD hybrid mismatch rules to address double deduction and deduction without inclusion mismatches in transactions between associated enterprises. For the purpose of the rules, a 50% interest requirement applies for enterprises to be considered as…