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  

Guide to Subdivision 832-H

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.


TABLE OF SECTIONS
TABLE OF SECTIONS
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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