Spain Consulting on Draft Law for Implementation of ATAD Hybrid Mismatch Rules

Spain's Ministry of Finance has published a draft law for consultation that includes amendments to the Corporate Tax Law and the Non-Resident Income Tax Law for the implementation of the hybrid mismatch rules of the EU Anti-tax Avoidance Directive. The consultation follows a reasoned opinion sent by the European Commission in November 2020 to remind Spain that it should have transposed the ATAD hybrid mismatch measures by 31 December 2019.

The measures of the draft law are in line with ATAD…