Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 832 - Hybrid mismatch rules  

Subdivision 832-G - Deducting hybrid mismatch  

Operative provisions

SECTION 832-540   When a deducting hybrid mismatch is an offshore hybrid mismatch  

832-540(1)    
A * deducting hybrid mismatch is an offshore hybrid mismatch if:

(a) the only * deduction components of the mismatch are * foreign income tax deductions; and

(b) 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, in any country in which a foreign income tax deduction arose.

Note:

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

832-540(2)    
The amount of the * offshore hybrid mismatch is the * neutralising amount for the * deducting hybrid mismatch.