Poland’s implementation of EU ATAD 2 anti-hybrid measures enters into force from 1 January 2021

From 1 January 2021, Polish regulations implementing the European Union (EU) Anti-Tax Avoidance Directive – ATAD 2¹ will enter into force. The purpose of the regulations is to prevent the exploitation of hybrid mismatches. Specifically, the regulations provide for non-deductibility of payments giving rise to a:

• Double deduction – where the same payment is deductible from the tax base in more than one jurisdiction
• Deduction without inclusion – if the payment is deducted from the tax base in Po…