The European legal framework to neutralize hybrid mismatches as a manifestation of tax avoidance

the transposition of eu anti-tax avoidance directives (Atad I & Atad II) in Spanish Law

Abstract

Tax avoidance represents an important challenge for International Tax Law. A decisive step was taken with the completion of the OECD BEPS Project. BEPS Action 2 was transposed into European Union Law by Anti-Tax Avoidance Directives -ATAD I & ATAD II- which compose the European Union Anti tax avoidance package. In March 2021, measures against tax avoidance regarding hybrid mismatches were transposed into Spanish Law. What is proposed is to analyze the issue regarding European Union Law and Spanish Law from the legal-tax point of view.