Bulgaria Publishes Law to Implement ATAD Reverse Hybrid Mismatch Rules

Bulgaria has published the Law Amending and Supplementing the Corporate Income Tax Act, which provides for the implementation of the reverse hybrid mismatch rules of the EU Anti-Tax Avoidance Directive as amended (ATAD2). This includes that where one or more foreign entities are affiliated undertakings and collectively hold directly or indirectly 50% or more of the voting rights, the share capital, or the right to profits of a hybrid entity incorporated or established in Bulgaria that is not…