In line with its obligations under Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (“ATAD”) and Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countries (“ATAD 2”), Ireland introduced Chapters 1 to 11 of Part 35C of the Taxes Consolidation Act 1997, giving effect to the majority of the recommendations in the Action 2 Report from 1 January 2020. Ireland introduced Chapter 10A of Part 35C of the Taxes Consolidation Act 1997 in relation to reverse hybrid mismatches with effect from 1 January 2022. A summary of the Chapters in Part 35C is set out below:
Chapter 1: Interpretation and general (Part 35C)
Chapter 2: Double deduction
Chapter 3: Permanent establishments
Chapter 4: Financial instruments 
Chapter 5: Hybrid entities
Chapter 6: Withholding tax
Chapter 7: Tax residency mismatch
Chapter 8: Imported mismatch outcomes
Chapter 9: Structured arrangements
Chapter 10: Carry forward
Chapter 10A: Reverse hybrid mismatches
Chapter 11: Application of this Part