Many European Union (EU) members have implemented legislation intended to eliminate “hybrid mismatches” arising from the differing tax treatment of a legal entity under the laws of two or more jurisdictions. This legislation has been promulgated under the OECD’s Anti-Tax Avoidance Directive II (ATAD2). United States taxpayers operating in the EU through local legal entities must understand how this could affect their tax compliance and planning.During this webinar, Plante Moran and Mazars international tax experts will discuss what ATAD2 is, how ATAD2 and anti-hybrid rules can affect entity structures, and withholding tax hybrid issues.
Learning objectives:
- Learn what ATAD2 is and how it can affect taxpayers
- Define the potential impact of ATAD2 and anti-hybrid rules on current and future entity structures
- Identify U.S. tax considerations for the anti-hybrid disallowance
- Learn about the withholding tax hybrid issues
