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The final reports on the 15 OECD Action Items against BEPS were released to the public on 5 October 2015. The Luxembourg law implementing the hybrid mismatch measures in ATAD 2 (2017/952 EU Anti-Tax Avoidance Directive) into domestic law was approved by the parliament and published on 23 December 2019.The ATAD 2 is largely inspired by Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the OECD’s base erosion and profit shifting project. Rules on reverse hybrid mismatches should apply to all entities that are treated as transparent for tax purposes by a Member State. Attempts to coordinate national tax regimes tends to get conflated with a grassroots passion for crackdown on BEPS risks. Member States should communicate to the Commission all information necessary for this evaluation. (4)  Council Directive 2011/96/EU of 30 November 2011 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (OJ L 345, 29.12.2011, p. 8). It should be understood that a mismatch outcome could arise if a payment made under a financial instrument is not included in income within a reasonable period of time. If the EU can’t implement the BEPS minimum standards in a more straightforward manner, who can? 4. It would thus allow inefficiencies and distortions to persist in the interaction of distinct national measures. According to the commission, Ireland was excluding one or more categories of entities that should not have been classified as financial undertakings. On 28 January 2016 the Commission presented its proposal for an Anti-Tax Avoidance Directive as part of the Anti-Tax Avoidance Package.On 20 June 2016 the Council adopted the Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market.. This means that if the payer jurisdiction allows the deduction to be carried forward to a subsequent tax period, the requirement to make an adjustment under this Directive could be deferred until such time as the deduction is actually set off against non-dual-inclusion income in the payer jurisdiction. It is one of the ways Belgium got itself in hot water. As empowered by Article 98(2) of the Income Tax Act, the Commissioner For Revenue has, on 31 August 2020, published a set of guidelines (the Guidelines) concerning the scope, interpretation and application of the Anti-Tax Avoidance Directives (ATAD) Implementation Regulations (S.L.123.187.) In order to provide for a comprehensive framework of anti-abuse measures the Commission presented its proposal on 25th October 2016, to complement the existing rule on hybrid mismatches. Perhaps member states’ appetite for cracking down on corporate base erosion shouldn’t be taken as a given. It may be relevant to note the following: i) The amount of non-distributed income to be included in the tax base of the Cypriot controlling entity is computed by applying the general tax framework and provisions of ATAD allows member states to adopt a grandfather clause excluding interest expense derived from loan obligations incurred before June 17, 2016. The anti-avoidance measures in the Anti-Tax Avoidance Directive other than the rule on hybrid mismatches, are: Controlled foreign company (CFC) rule:  to deter profit shifting to a low/no tax country. In respect of payments made by a hybrid entity to its owner, or deemed payments made between the head office and permanent establishment or between two or more permanent establishments, a hybrid mismatch could arise where the deduction without inclusion outcome results from the payment or deemed payment not being recognised in the payee jurisdiction.

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