Czech Republic to Adopt Amendment to Parent-Subsidiary Directive Concerning Hybrid Mismatches

The Czech government has submitted legislation to parliament to adopt the amendment to the EU Parent-Subsidiary Directive concerning hybrid mismatch arrangements. Under the new rule, the participation exemption provided for under the Directive will be denied if a dividend received is tax deductible for the distributing subsidiary in its country of residence. The additional general anti-abuse provision that was added to the Directive will not be adopted in the Czech Republic, as the country's …