The Confédération Fiscale Européenne (CFE) has reached agreement on the finalised text of the Anti-Tax Avoidance Directive 2 (ATAD2). The Directive extends the scope of the original Anti-Tax Avoidance Directive (ATAD) to include hybrid mismatches involving non-EU member states and will tackle specific hybrid scenarios, e.g. those relating to permanent establishments, dual resident entities and hybrid financial instruments, reports CCH Daily.
Contention on two carve-outs and the implementation deadline still has to be resolved. ATAD’s implementation deadline is 31 December 2018, whereas ATAD 2 will mostly have a deadline of 31 December 2019.
The European Parliament must now issue an Opinion, after which the Council will adopt the Directive.