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  • Hybrid mismatch rules – practical compliance guideline published

    We are committed to helping you manage your compliance risks where you want to eliminate hybrid tax outcomes that would otherwise fall within the newly legislated hybrid mismatch rules.

    Accordingly, we have released Practical Compliance Guideline PCG 2018/7 Part IVA of the Income Tax Assessment Act 1936 and restructures of hybrid mismatch arrangements

    This PCG will help you and your advisers manage your compliance risk by outlining straightforward (low risk) restructuring to which we won't seek to apply Part IVA. We encourage you to engage with us early if you fall outside the low-risk parameters outlined in the PCG.

    The hybrid mismatch rules can apply from as early as 1 January 2019 and are aimed at deterring the use of certain hybrid arrangements that exploit differences in the tax treatment of an entity or financial instrument under the income tax laws of two or more countries. This can result in double non-taxation or long term tax deferral.

    If you are potentially affected by the rules and are considering restructuring, you should refer to this PCG to understand our compliance approach.

    We are also currently working on a range of guidance products which will provide further support to those potentially impacted by the hybrid mismatch rules.

    See also:

      Last modified: 31 Oct 2018QC 57266