Income Tax (Transitional Provisions) Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 830 - Application of the foreign hybrid rules  

SECTION 830-1   Standard application  


Foreign hybrids

830-1(1)    
Division 830 of the Income Tax Assessment Act 1997 applies to assessments for the 2003-2004 income year, and each later income year, of a taxpayer who will as a result be a partner in an entity that is a foreign hybrid in relation to that income year.

CFCs that are, directly or indirectly, partners in foreign hybrids

830-1(2)    
Division 830 of the Income Tax Assessment Act 1997 applies for the purpose of working out the attributable income, in relation to an attributable taxpayer, for:


(a) the statutory accounting period that starts on 1 July 2003 or on the day on which, as a result of an election under subsection 319(2) of the Income Tax Assessment Act 1936 , the statutory accounting period that would otherwise start on 1 July 2003 starts; and


(b) each later statutory accounting period;

of a CFC that:


(c) will as a result be a partner in an entity that is a foreign hybrid in relation to that statutory accounting period; or


(d) has, directly or indirectly through one or more other entities, an interest in another entity that will, as a result, be a foreign hybrid in relation to that statutory accounting period.



 

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