The Netherlands has published Decree no. 2021-20014 of 1 October 2021 in the Official Gazette, which entered into force on 11 October 2021 and provides guidance on the application of the hybrid mismatch rules introduced from 1 January 2020 in accordance with the EU Anti-Tax Avoidance Directive (ATAD) as amended. This includes hybrid mismatch rules to address double deduction and deduction without inclusion mismatches.
One of the key aspects of the decree concerns the so-called origin requi…