Sweden Begins Consultation On Anti-Hybrid Rules
Ulrika Lomas, Tax-News.com, Brussels
27 September, 2019
On September 20, 2019, the Swedish Ministry of Finance commenced a consultation on proposals to tackle hybrid mismatch arrangements.
The proposals would implement the second European Union Anti-Tax Avoidance Directive (ATAD 2), which is designed to prevent multinationals from accessing unfair advantages by using hybrid mismatch arrangements to exploit differences in the tax treatment of an entity or financial instrument under the income tax laws of two or more countries.
ATAD 2 addresses hybrid mismatches with regard to non-EU countries, given that intra-EU disparities are already covered by the first ATAD, adopted in July 2016.
Member states are required to transpose ATAD 2 into national law and regulations by December 31, 2019. However, it is proposed that the Swedish provisions will enter into force on January 1, 2021.
Additionally, the Swedish measures include supplementary proposals regarding reverse hybrid arrangements, which member states are required to implement from 2022.
The consultation is restricted to a specific list of governmental and private sector organisations, and submissions must be made by December 19, 2019.