Italian Tax Authorities Issue Public Ruling on Imported Hybrid Mismatches

Journal
Schiavello, S.; Rossi, R.; Ratti, C.
Italy
European Taxation 2023 (Volume 63), No. 8
FormatPDF
EUR
40
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45 (VAT excl.)

In this note, the authors comment on Italian Ruling No. 288/E, which clarifies the circumstances in which a hybrid mismatch should be deemed to exist as a result of the imported hybrid mismatch rule being triggered in a situation involving an Italian company that is part of a multinational enterprise group.