Income Tax (Transitional Provisions) Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 832 - Hybrid mismatch rules  

Subdivision 832-A - Application of Division 832 of the Income Tax Assessment Act 1997  

SECTION 832-15   Application of imported hybrid mismatch rule  

832-15(1)    
Subdivision 832-H (Imported hybrid mismatch) of the Income Tax Assessment Act 1997 applies to assessments for income years starting on or after 1 January 2019.

832-15(2)    
However, in applying Subdivision 832-H to assessments for income years starting before 1 January 2020, items 2 and 3 of the table in subsection 832-615(2) are to be disregarded.

832-15(3)    
Despite subsection (1), Subdivision 832-H does not apply in relation to an offshore hybrid mismatch unless a deduction component of the mismatch arose in a foreign tax period that ends in an income year starting on or after 1 January 2019.

832-15(4)    
In determining whether subsection (3) is satisfied in relation to an offshore hybrid mismatch, disregard section 832-635 of the Income Tax Assessment Act 1997 .