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This session will examine the practical application of anti-hybrid rules, commencing with the OECD Action 2 report and its recommendations, before considering the EU Anti-Tax Avoidance Directive and its local transposition. It will also address real-world compliance challenges and the latest relevant proposals affecting practitioners.

When
Thursday, 24 September 2026
Time
09:00 - 12:00
Venue
In-person (venue to be confirmed)
Speakers
Ruth Bonnici

ATAD in-practice (anti-hybrid, Hybrid mismatches)

This seminar will examine the OECD Rules, as adopted by various jurisdictions worldwide, how they have impacted structures, with particular attention to the impact on Malta, and how they differ from the EU’s ATAD. The focus will then shift to ATAD 2, the update to ATAD that enacted anti-hybrid rules in the EU, and the local transposition thereof in view of the opt outs adopted by Malta.

Beyond the legislative framework, the session will focus on practice and compliance challenges, structural implications, and grey areas that practitioners encounter when applying these rules to real transactions and client structures.

 

Level: INTERMEDIATE

 

These sessions are not eligible for the Membership Offer.

 


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3 CPE Core Hours

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Ruth Bonnici

Ruth is a Director within KPMG Malta’s international tax advisory team, where she specialises in supporting foreign clients seeking to establish a presence in Malta, restructure their holdings, or arrange financing via Malta with a particular expertise in the iGaming sector. As a warranted lawyer, Ruth also holds an Advanced Masters in International Taxation from the International Tax Centre at the University of Leiden. She is also a regular lecturer, delivering sessions on a range of international and domestic tax topics.