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Tax & Legal Newsflash – Italy issues draft circular on hybrid mismatch arrangements


The Italian Tax Authorities (ITA) launched, on October 18, a public consultation on the draft interpretative Circular Letter (the ‘Draft Circular’), which, at 111 pages, covers the application of the hybrid mismatch arrangements rules (the ‘Hybrid Rules’) as governed by Legislative Decree 142/2018 (the ‘ATAD Decree’) that implements the ATAD Directives through domestic italian legislation.

Newsflash EN_11_2021_Italy issues draft circular on hybrid mismatch arrangements