Bestrijding van hybride mismatches in de Nederlandse vennootschapsbelasting ; Measures against hybrid mismatches in het Dutch Corporate Tax

The article deals with new measures laid down in the Dutch corporate tax against so called hybrid mismatches. These mismatches offered opportunities for international active groups (MNE's) to substantially reduce their international corporate tax base. Based on the action plans of the OECD against base erosion and profit shifting the EU introduced ATAD 2 which deals with the aforementioned hybrids. The new Dutch legislation discussed in the article is the implementation of ATAD 2 in the Netherlands.