Anti-Tax Avoidance Directive; Exit Taxation & Hybrid Mismatches

As from 1 January 2020 the law in entered into force, as regards exit taxation, hybrid mismatches and tax residency mismatches and as from 01 January 2022 as regards reverse hybrid mismatches.

Exit Taxation
In certain cases, when a taxpayer moves assets (e.g. from head office to permanent establishment or vice versa) or its tax residence out of the Republic, the taxpayer shall be subject to tax on an amount equal to the market value of the transferred assets, at the time of exit, less their value for tax purposes.

The taxpayer has the right to defer the payment of the exit tax by paying it in instalments over five years.

Hybrid mismatches
Hybrid mismatches rules may apply to deny a deduction or tax an income in the Republic, to the extent hybrid mismatches result in double deduction or deduction without inclusion.