Prevention of hybrid arrangements through the planned ATAD implementation law
In December, the German Federal Ministry of Finance (BMF) published the "Draft Law on the Implementation of the Anti-Tax Avoidance Directive (ATAD)".
The draft bill, which is intended to transpose the EU's ATAD directives into national law, contains far-reaching changes to the rules on international tax law. We have already presented an overview of the draft bill in our International Tax Update. In the following, we would like to take a closer look at the proposed regulations on hybrid structures.