Income Tax Assessment Act 1997
The amount of the *imported hybrid mismatch is the lesser of:
(a) the importing deduction amount worked out under subsection (2) in relation to the deduction; and
(b) the amount worked out using the following formula:
|Importing deduction||×||Remaining offshore hybrid mismatch|
|Total importing deductions of equal priority|
importing deduction means the amount of the importing deduction amount worked out under subsection (2) in relation to the deduction.
remaining offshore hybrid mismatch means:
total importing deductions of equal priority means the amount worked out by:
The amount (the importing deduction amount ) worked out under this subsection in relation to a deduction or *foreign income tax deduction is:
(a) if the *importing payment is made directly to the offshore deducting entity - the amount of the deduction or foreign income tax deduction; or
(b) if the importing payment is made indirectly through one or more interposed entities to the offshore deducting entity - the lesser of:
(i) the amount of the deduction or foreign income tax deduction; and
(ii) the smallest amount of any foreign income tax deduction to which a payment by an interposed entity gave rise.