Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 832 - Hybrid mismatch rules  

Subdivision 832-B - Concepts relating to mismatches  

Operative provisions

SECTION 832-135   832-135   Safe harbour for translation rates  


If:


(a) a payment has any of the following effects:


(i) it gives rise to a deduction;

(ii) it gives rise to a *foreign income tax deduction;

(iii) it is *subject to Australian income tax;

(iv) it is *subject to foreign income tax; and


(b) for the purposes of this Division, the amount of one or more such effects is to be translated under Subdivision 960-C into an entity ' s *applicable functional currency, or into Australian currency;

then it is reasonable for the purposes of item 11A of the table in subsection 960-50(6) (as modified by the regulations) to apply an exchange rate to each translation so as best to achieve a consistent measure of the extent to which the payment had each such effect.

Note:

Item 11A is added to the table in subsection 960-50(6) by the regulations.


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