11 February 2020
Romania has published Ordinance no. 6 of 28 January 2020 in the Official Gazette, which provides for the implementation of the hybrid mismatch measures of the EU Anti-Tax Avoidance Directive as amended (ATAD2). This includes measures to address double deduction and deduction without inclusion mismatch outcomes between associated companies, a head office and its permanent establishment, between two permanent establishments of the same entity, or in the framework of a structured arrangement. In general, a hybrid mismatch is addressed by either denying a deduction or requiring an inclusion of income. Where a deduction is denied, taxpayers are eligible for compensation in the event of dual inclusion income, whether arising in the current or subsequent fiscal period.
The Ordinance entered into force on 3 February 2020, although as per the Directive, the hybrid mismatch measures generally apply from 1 January 2020.
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