The Government Ordinance no. 6/2020 amending and supplementing Law no. 227/2015 regarding the Tax Code, and regulating tax and budgetary measures, was published in the Official Journal no. 72/2020.
According to the explanatory note, the pronouncement mainly transposes the following provisions of the Council of the European Union into national Romanian law:
In the field of corporate income tax, the provisions regarding the hybrid mismatches from Council Directive 2016/1.164/EU laying down rules against practices to avoid tax obligations that have a direct impact on the functioning of the internal market, Council Directive 2017/952/EU amending Directive 2016/1.164/EU regarding the hybrid mismatches involving third parties.
Directive 2016/1.164/EU amended by Directive 2017/952 lays down rules against the practices to avoid tax obligations, employed by some groups of companies involved in hybrid arrangements, that take advantage of the differences in the tax treatment applicable to hybrid entities/ hybrid financial instruments, according to the law of one or several tax jurisdictions, thus being beneficial to the business environment by promoting fair tax systems in the Member States of the European Union and in relation to third countries.
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