An overview of the anti-hybrid rules in ATAD II that entered into force on 1 January 2020 and their expected application in practice in a domestic context.

Wednesday, 11 March 2020
09:00 - 12:00
The Notch Conference Centre, Urban Valley Resort, Kappara
Mr Steve Gingell
Dr. Christopher Bergedahl

Adjusting to anti-hybrid legislation in Malta

This seminar aims to discuss the transposition of Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countries (ATAD 2) into Maltese law by way of LN 348 of 2019.

Specifically, the session shall address the following matters:

  • A review of the structural features of LN 348 of 2019;
  • An overview of the species of hybrid arrangements targeted; and
  • An assessment from a Maltese perspective of the financial instruments, legal forms and arrangements that may fall within the scope of ATAD 2;
  • Practical considerations when advising upon anti-hybrid legislation.

This seminar shall also constitute a direct follow-up to an internal MIT Think-Tank (comprising of members of the MIT Council and the MIT Direct Tax Committee) on anti-hybrid rules in Malta. The Speakers shall present the findings of that Think-Tank – whose contents shall eventually be developed into a MIT Position Paper on LN 348 of 2019 – in furtherance of developing a common level of understanding of the legislation’s major points of contention.


COMPLIMENTARY PARKING is available for participants in The Notch Conference Centre car park (on a first-first, first-served basis)

In case of group bookings kindly contact [email protected]

3 core CPE hours

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Mr Steve Gingell

Steve is a tax partner with PwC. In 2005, Steve completed a Masters in Law, with a specialisation in tax, at the University of London. He then worked with PwC in London for a two year period, dealing with international tax structuring projects and UK corporate tax matters.

Steve is heavily involved in advising a wide variety of local and international corporate clients operating in various industries on various Maltese tax related matters. Steve also lectures at the University of Malta and is an examiner for dissertations submitted by students reading for a Masters in Accountancy.

Dr. Christopher Bergedahl

Christopher is a Manager at Deloitte Malta having joined in 2014 as part of its LL.D. Pathway Programme.  Christopher provides support in  both local and foreign client engagements within the team.

In 2017 he graduated summa cum laude from the International Tax Center Leiden following which he served as a Teaching Assistant for the Fall Term of the 2017-2018 class.