Royal Decree of the Spanish Gazettes amending the Corporate Earnings Tax Legislation in accordance with EU directives on hybrid mismatches

Daily tax report: International

March 15, 2021, 5:00 a.m.


The Spanish Official Gazette of March 10th published the Royal Decree No. 4/2021 amending the Corporate Income Tax Act in order to partially implement the EU Avoidance Directive ATAD1 in the version of ATAD 2 in relation to hybrid mismatches with non-EU countries. The decree includes measures: 1) Implement hybrid mismatch rules in line with Action 2 of the OECD Project on Erosion and Profit Shifting (BEPS), ATAD1 and ATAD2; 2) Clarification of hybrid mismatch agreements in which non-EU countries and permanent establishments are involved; and 3) implementation of rules to limit the deduction for other expenses. The decree comes into force on March 11th and usually comes into effect for tax periods that …

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