The Anti-Tax Avoidance Directive 2 and Hybrid Financial Instruments: Countering Deduction and Non-Inclusion Schemes in Third-Country Situations

This article analyses the second Anti-Tax Avoidance Directive and its role in countering deduction and non-inclusion schemes caused by the use of hybrid financial instruments in third-country situations, in the light of primary EU law and Action 2 of the OECD/G20 Base Erosion and Profit Shifting initiative and its underlying justifications.