Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 832 - Hybrid mismatch rules  

Subdivision 832-F - Branch hybrid mismatch  

Operative provisions

SECTION 832-455   Deduction not allowable  

832-455(1)  
This section applies to an entity if:


(a) apart from this section, the entity would be entitled to a deduction in an income year in respect of a payment; and


(b) the deduction is the *deduction component of a *branch hybrid mismatch to which the payment gives rise.

832-455(2)  
So much of the deduction as does not exceed the amount of the *branch hybrid mismatch is not allowable as a deduction.

832-455(3)  
However, this section does not apply in relation to the *branch hybrid mismatch if subsection 23AH(2) of the Income Tax Assessment Act 1936 does not apply in relation to the payment because of subsection (4A) of that section.


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