The French tax authority published guidance BOI-IS-BASE-80 on 15 December 2021 regarding the application of the measures to counter hybrid mismatches. The guidance covers the measures implemented in compliance with the EU Anti-Tax Avoidance Directive as amended (ATAD1 and ATAD2) as part of the Finance Law for 2020. The guidance includes three main sections/headings:
- The definitions of the concepts mentioned in the hybrid mismatch rules (BOI-IS-BASE-80-10);
- The scope of the rules and correcti…