Directive (EU) 2016/1164 has incorporated a new provision addressing the new case of inverted hybrid asymmetries


Key Points:

  • Certain entities under the income attribution system (fiscally transparent) must pay corporate income tax, ceasing to attribute the income obtained to their partners.
  • This change will affect cases in which a hybrid mismatch, i.e., situations in which the income obtained by fiscally transparent entities is not taxed either by its participants or by the entity paying such income.


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