On 29 May 2017, the Council of the European Union announced the adoption of the Council Directive (ATAD 2) amending the Anti-Tax Avoidance Directive (EU) 2016/1164 (ATAD 1) as regards hybrid mismatches with third (non-EU) countries. The ATAD 1 was approved in July 2016 and introduced rules addressing intra-EU hybrid mismatches, as well as other BEPS-related issues ({News-2016-07-14/A/4- previous coverage}). Beyond extending the rules to third countries, ATAD 2 also expands upon the hybrid m…