Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024

CHAPTER 8 - ADMINISTRATION  

PART 8-2 - SAFE HARBOURS  

Division 2 - Transitional CbCR Safe Harbour  

Subdivision G - Treatment of Hybrid Arbitrage Arrangements  

SECTION 8-150  

8-150   ARRANGEMENT TREATED AS HAVING BEEN ENTERED INTO AFTER 15 DECEMBER 2022  
For the purposes of this Subdivision, treat an arrangement as having been entered into after 15 December 2022 if:

(a)    the arrangement is amended or transferred after 15 December 2022; or

(b)    the performance of any rights or obligations at any time after 15 December 2022 under the arrangement differs from the performance of those rights or obligations on or before 15 December 2022 (including where payments are reduced or ceased with the effect of increasing the balance of a liability); or

(c)    there is a change in the accounting treatment with respect to the arrangement after 15 December 2022.