Subsidiary Legislation S.L123.187 (https://legislation.mt/eli/sl/123.187/eng) transposes the provisions af ATAD II (Council Directive 2017/952).The Reverse Hybrid mismatches article was applicable as from 1 January 2022.                                                                      As regards 2.2 hereunder, this is being ticked as "Yes" bearing in mind the transposition of the anti-hybrid rule within the Parent Subsidiary Directive, but also (for other cases) in view of issuance of Guidance by MTCA that income from a loan which has the characteristics of both debt and equity benefits from no exemption related to income from participating holdings (https://mtca.gov.mt/personal-tax/legal-and-technical/test/guidelines-on-the-tax-treatment-of-interest-from-a-loan). This takes priority over any possible overlap with ATAD II, as per Rectial 30 therein.