Article
Dutch Ministry Of Finance Updates Hybrid Mismatch Decree: Broader Guidance And New Practical Examples
The Dutch Ministry of Finance has issued an updated Decree providing crucial clarifications on the practical application of hybrid mismatch rules under ATAD2. These updates address key interpretative questions that have emerged in practice, particularly concerning the interaction with US tax regimes, capitalised acquisition costs, and cost-plus transfer pricing structures.
Loyens & Loeff