The area of mismatches, which deals with issues such as hybrid loans and hybrid entities, and differences in the qualification of such structures between jurisdictions, is an area of particular importance. Detailed discussions with Member States have shown that in a specific case an agreed solution cannot be achieved without a legislative amendment of the Parent-Subsidiary Directive. The objective will be to ensure that the application of the directive does not inadvertently prevent effective action against double non-taxation in the area of hybrid loan structures.
