Income Tax Assessment Act 1997
CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX
PART 4-5 - GENERAL
Division 832 - Hybrid mismatch rules
Subdivision 832-H - Imported hybrid mismatch
Guide to Subdivision 832-H SECTION 832-605 What this Subdivision is about
This Subdivision neutralises an imported hybrid mismatch. This mismatch is an integrity rule that applies when one or more entities are interposed between a hybrid mismatch and a country that has hybrid mismatch rules.
Identifying an imported hybrid mismatch involves testing whether a hybrid mismatch involving 2 foreign countries has been " imported " into Australia by a deduction. If so, there are priority rules that allocate the neutralisation of the mismatch between countries that have hybrid mismatch rules.
|832-610||Deduction not allowable|
|832-615||When a payment gives rise to an imported hybrid mismatch|
|832-625||Meaning of importing payment|
|832-630||Working out the amount of the imported hybrid mismatch|
|832-635||Carry forward of residual offshore hybrid mismatches|
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