Income Tax Assessment Act 1997
SECTION 832-605 What this Subdivision is about
This Subdivision neutralises an imported hybrid mismatch. This mismatch is an integrity rule that applies when one or more entities are interposed between a hybrid mismatch and a country that has hybrid mismatch rules.
Identifying an imported hybrid mismatch involves testing whether a hybrid mismatch involving 2 foreign countries has been " imported " into Australia by a deduction. If so, there are priority rules that allocate the neutralisation of the mismatch between countries that have hybrid mismatch rules.
Operative provisions | |
832-610 | Deduction not allowable |
832-615 | When a payment gives rise to an imported hybrid mismatch |
832-620 | Hybrid mismatch |
832-625 | Meaning of importing payment |
832-630 | Working out the amount of the imported hybrid mismatch |
832-635 | Carry forward of residual offshore hybrid mismatches |
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