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January 27, 2020

Tuesday, 4 February | EUís anti-hybrid mismatch rules are in effect as of January 1, 2020: Are you ready? (12 pm ET)

Ringing in the new year, the European Union’s (EU) anti-hybrid mismatch rules became effective as of January 1, 2020!

The EU’s 2017 Council Directive 2017/952 (ATAD II) mandated EU member states to implement anti-hybrid mismatch rules into local law by December 31, 2019. Many member states, such as Luxembourg, the Netherlands and France, completed their domestic legislation quite late in December 2019. The German legislative adoption process was started even later with a December 2019 draft bill that was quickly retracted; a revised version is expected in late January 2020 at the earliest.

Although the ATAD II defines the general framework of the hybrid mismatch rules, the recent legislative developments reflect that its local implementation is not fully harmonized within the EU and that each EU member state may have captured the complexity of the matter with a varying degree of sophistication. As of January 1, 2020, any assessment of the impact of the hybrid mismatch rules on any intercompany arrangement will require in-depth knowledge of the locally applicable law in multiple jurisdictions. Careful study and interpretation of hybrid mismatch rules in multiple EU jurisdictions will become the new normal and a required procedure for intercompany transactions with EU member state businesses.

The objective of this special edition webcast is to provide an up-to-date overview of the ATAD II implementation in the EU. Comparisons to, and interactions with, the US anti-hybrid rules will also be discussed. Panelists will present the latest legislative developments and “hot spot” examples applicable to all EU jurisdictions, including:

  • Germany (with discussion of far-reaching new statutory proposals for transfer pricing of intercompany lending arrangements which were inserted into the German ATAD draft bill)
  • United Kingdom
  • Luxembourg

Date: Tuesday, 4 February 2020

Time: 12:00–1:15 p.m. EST New York; 9:00 a.m. PST Los Angeles; 17:00 London; 18:00 Paris

Registration: Register for this event.


  • Tobias Appl, German Tax Desk, International Tax and Transaction Services, Ernst & Young LLP

  • Ronny Waldkirch, EMEIA Transfer Pricing Desk, International Tax and Transaction Services, Ernst & Young LLP

  • Matthew Williams, UK Tax Desk, International Tax and Transaction Services, Ernst & Young LLP

  • Jurjan Wouda Kuipers, Financial Services Tax Desks, International Tax and Transaction Services, Ernst & Young LLP

  • Lee Holt, Director of Capital Markets Tax, International Tax and Transaction Services, Ernst & Young LLP


  • Gerrit Groen, Director, Global Tax Desks Network, International Tax and Transaction Services, Ernst & Young LLP

CPE credit offered: 1.5. Recommended field of study: Taxes. Learning objective: Understand the ATAD II implementation in the EU and comparisons to, and interactions with, the US anti-hybrid rules. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling, length of participation, etc. See CPE FAQ for more information.

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The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.


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