Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 832 - Hybrid mismatch rules  

Subdivision 832-J - Integrity rule  

Operative provisions

SECTION 832-730   Back to back arrangements, etc.  

832-730(1)  
Subsection (2) applies if:


(a) an entity (the original paying entity ) makes a payment of a kind mentioned in subparagraph 832-725(1)(d)(i) to another entity; and


(b) the other entity, or a further entity, pays an amount of that kind to a foreign entity; and


(c) the payments mentioned in paragraphs (a) and (b) are made under an arrangement involving back-to-back loans or an arrangement that is economically equivalent and intended to have a similar effect to back-to-back loans.

832-730(2)  
For the purposes of this Subdivision, treat the original paying entity as having made the payment mentioned in paragraph (1)(a) to the foreign entity mentioned in paragraph (1)(b).


This information is provided by CCH Australia Limited Link opens in new window. View the disclaimer and notice of copyright.