Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 830 - Foreign hybrids  

Subdivision 830-D - Special rules applicable when an entity becomes or ceases to be a foreign hybrid  

Note:

In the case of a foreign hybrid company, references in this Subdivision that relate to partnerships are to be read subject to Subdivision 830-B . For example, a reference to a partner will be a reference to a shareholder in the company who is treated by Subdivision 830-B as a partner.

SECTION 830-80   Setting the tax cost of partners ' interests in the assets of an entity that becomes a foreign hybrid  

830-80(1)    
This section applies if:

(a) an entity is a *foreign hybrid in relation to an income year (the hybrid year ); and

(b) the entity was in existence at the end of the preceding income year (which may be the income year before this Division first applies to the entity); and

(c) the entity was not a foreign hybrid in relation to that preceding income year.

830-80(2)    
For the purposes of applying an *asset-based income tax regime for the hybrid year and each later income year in relation to which the entity continues to be a foreign hybrid, the *tax cost is set at the start of the hybrid year, for each asset of the *foreign hybrid in which each partner has an interest at that time.