Ricardo Seabra Moura (Managing Associate) and Rita Pereira Abreu (Associate) write an article for ITR - International Tax Review on the Anti Tax Avoidance Directive – ATAD 1, in which they analyse the challenges that lay ahead following the implementation of the rules.

"The implementation of anti-hybrid mismatch arrangement rules has mainly involved a mere ‘copy and paste’ of the wording of ATAD II to a new chapter of the corporate income tax (CIT) code. The fact that hybrid mismatch arrangement rules were completely innovative vis-à-vis the Portuguese legal framework may have led the legislator to simply replicate in domestic law the rules foreseen in ATAD II."

Read the article here.