Executive summary

The Italian Tax Authorities issued Circular Letter n. 2/2022 on hybrid mismatch rules (the Circular) in January 2022. The Circular provides interpretations and examples on the provisions governed by Decree 142/2018 which implemented the European Union (EU) Anti-Tax Avoidance Directive (ATAD) in domestic law. The Circular follows a public consultation period (from October 2021 to 1…