Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 832 - Hybrid mismatch rules  

Subdivision 832-C - Hybrid financial instrument mismatch  

Operative provisions

SECTION 832-195   When a hybrid financial instrument mismatch is an offshore hybrid mismatch  

832-195(1)  
A *hybrid financial instrument mismatch is an offshore hybrid mismatch if:


(a) the *deduction component of the mismatch is a *foreign income tax deduction; and


(b) no amount becomes *subject to Australian income tax as a result of the application of section 832-185 in relation to the mismatch; and


(c) the mismatch is not covered by *foreign hybrid mismatch rules that correspond to this Subdivision, or by a law that has substantially the same effect as foreign hybrid mismatch rules that correspond to this Subdivision.

Note:

An offshore hybrid mismatch might give rise to an imported hybrid mismatch: see Subdivision 832-H .

832-195(2)  
The amount of the *offshore hybrid mismatch is the amount of the *hybrid financial instrument mismatch.


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