In a recent letter to parliament, the Dutch Ministry of Finance clarified the implementation of the hybrid mismatch amendment to the Parent-Subsidiary Directive, which was approved as part of the Dutch Tax Plan for 2016 ({News-2015-12-28/A/5-previous coverage}). The amendment to the Directive provides that the participation exemption will not be granted for dividends if deductible for the distributing subsidiary. The letter clarifies that the Dutch companies receiving dividends from a foreign…