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Czech Senate Passes Amendment Concerning Hybrid Mismatches under the Parent-Subsidiary Directive — Orbitax Tax News & Alerts

The Czech Senate (upper house of parliament) has reportedly passed legislation implementing the amendment to the EU Parent-Subsidiary Directive concerning hybrid mismatch arrangements. Under the new rule, the participation exemption provided for dividends will be denied if a dividend received is tax deductible for the distributing subsidiary in its country of residence. The legislation h...