On 29 October 2018, the Dutch government published a preliminary proposal implementing rules on hybrid mismatches as required under the amended EU Anti-Tax Avoidance Directive (ATAD2). This proposal is published for consultation purposes and is open for consultation until 10 December 2018.

The ATAD2 rules should be implemented by the Member States on 31 December 2019, albeit that the rule targeting reverse hybrid entities (see below) may be implemented later, but at the latest on 31 December 2021.