Belgium has transposed ATAD 2 as well as the directive of 8 July 2014 amending the PSD. The rules adopted in Belgium in view of those transpositions are similar to those recommended in the reports "Neutralising the effects of branch mismatch arrangements" and "Neutralising the effects of hybrid mismatch arrangements". The following rules adopted in Belgium are similar to those recommended in the report "Neutralising the effects of branch mismatch arrangements": 
1) Denial of the exemption for income attributable to a disregarded PE (recommendation 1). 
2) Non-deductibility of a payment made to an entity with one or more PE, if not included in the taxable income of the payee as a result of differences in the allocation of payment between the head office and PE or between two or more PE of the same entity (recommendation 2 1 a). 
3) Non-deductibility of a payment made to a disregarded PE (recommendation 2 1 b). 
4) Non-deductibility of a deemed payment between the PE and the head office or between two PE, if not included in the taxable income of the payee (recommendation 3). 
5) Non-deductibility, in the hands of the parent, of a payment made by a hybrid PE, if deductible in the payer jurisdiction (recommendation 4 1 a). 
6) Non-deductibility of a payment, in the hands of the payer, of a payment made by a hybrid PE, if deductible in the parent jurisdiction (recommendation 4 1 b). 
7) Non-deductibility of a payment that funds directly or indirectly deductible expenditure giving rise to a hybrid mismatch, except to the extent that one of the other jurisdictions involved has made an equivalent adjustment in respect of such hybrid mismatch (recommendation 5). 
8) Denial of tax transparency for reverse hybrids (recommendation 5 2), except for CIV's. 
9) Non-deductibility, in the hands of the parent, of a payment made by a hybrid entity, if deductible in the payer jurisdiction (recommendation 6 1 a). 
10) Non-deductibility, in the hands of the payer, of a payment made by a hybrid entity, if deductible in the parent jurisdiction (recommendation 6 1 b). 
11) Non-deductibility of a payment made by a company which is a resident of Belgium and of another jurisdiction, if deductible in this other jurisdiction (recommendation 7). If both jurisdictions are EU Member States, the payment remains deductible if the company is deemed to be a resident of Belgium according to the tax treaty in force between the two EU Member States. 
12) Non-deductibility of a payment that funds directly or indirectly deductible expenditure giving rise to a hybrid mismatch, except to the extent that one of the other jurisdictions involved has made an equivalent adjustment in respect of such hybrid mismatch (recommendation 8).