Italy Consulting on Draft Circular Providing Guidance on Hybrid Mismatch Rules

The Italian Revenue Agency has launched a public consultation on a draft circular providing guidance on the hybrid mismatch rules introduced as part of Decree No. 142 of 2018, which transposed the measures of the EU Anti-Tax Avoidance Directive (ATAD). This includes the hybrid mismatch rules of the ATAD as amended (ATAD2) to address double deduction and deduction without inclusion mismatches, including in relation to hybrid instruments, hybrid transfers, hybrid entities, and disregarded perm…