The Role of Pillar Two in Neutralizing Hybrid Mismatches: Complementary to or Overlapping with ATAD?
This thesis investigates and reflect on the interplay between the EU’s Anti-Tax Avoidance Directive (ATAD) and the OECD’s Pillar Two framework in neutralizing hybrid mismatch arrangements. The research goal is to determine the extent to which these regimes complement or overlap in mitigating hybrid mismatch outcomes. Final findings reveal that ATAD applies a direct, transaction-level approach, by
