Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 832 - Hybrid mismatch rules  

Subdivision 832-H - Imported hybrid mismatch  

Operative provisions

SECTION 832-635   Carry forward of residual offshore hybrid mismatches  

832-635(1)    
Subsection (2) applies if:

(a) a payment made in a particular *foreign tax period gave rise to an *offshore hybrid mismatch (the original mismatch ); and

(b) the original mismatch is only partly neutralised by the application of this Subdivision and equivalent provisions of applicable *foreign hybrid mismatch rules.

832-635(2)    
This Subdivision applies as if:

(a) the offshore deducting entity had made a payment in the next *foreign tax period; and

(b) the payment gave rise to an *offshore hybrid mismatch (the residual mismatch ); and

(c) the amount of the residual mismatch was the amount of the original mismatch that was not neutralised by the application of this Subdivision and equivalent provisions of applicable *foreign hybrid mismatch rules.