This alert summarizes the technical and practical implications of the Dutch Anti-Hybrid Rules. We specifically address the potential overkill that applies to US multinational companies with entities in their structure that are 'checked' as disregarded for US federal income tax purposes.

On 17 December 2019, legislation implementing the EU Anti-Tax Avoidance Directive 2 (“ATAD 2”) in Dutch tax law has been adopted and will have effect as of 1 January 2020 (i.e. financial years starting on or after 1 January 2020). All EU Member States are obliged to implement ATAD 2.

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