Executive summary
On 21 September 2021, the Netherlands has published draft legislation to implement specific reverse hybrid entity provisions as mandated by the European Union (EU) Anti-Tax Avoidance Directive II (ATAD II). These provisions counteract hybrid mismatches resulting from reverse hybrid entities, i.e., entities that are considered transparent from a Dutch tax perspective and if at least 50% of the voting rights, capital interests or profit rights in the entity are directly or indirec…