Spain implements reverse hybrid mismatches rule under EU ATAD 2

The Spanish Council of Ministers has approved an RDL through which the reverse hybrid mismatch rules under the European Union (EU) ATAD 2 will be implemented.

These rules were published on 19 October 2022 and are effective as from 1 January 2022.

Where the relevant requirements are met, the Spanish reverse hybrid entity will become a Spanish Corporate Income Tax taxpayer.