Abstract
Among tax practitioners, the interrelationship between the EU anti-hybrid rules in ATAD 2 (2017/952) Council Directive (EU) 2017/952 of 29 May 2017 Amending Directive (EU) 2016/1164 as Regards Hybrid Mismatches with Third Countries, Primary Sources IBFD [ATAD 2]. and the US "check-the-box" regulations have been a source of debate since the initial drafts of ATAD 2. The debate seems to have reached a dead end in respect of intercompany services remunerated on a "cost-plus" basis. The present article, against this background, focusses on an actual case for the purpose of illustrating certain unreasonable effects produced by the Italian anti-hybrid legislation.
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