Income Tax Assessment Act 1997
CHAPTER 4
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INTERNATIONAL ASPECTS OF INCOME TAX
Subsection (2) applies if:
(a) a payment made in a particular *foreign tax period gave rise to an *offshore hybrid mismatch (the original mismatch ); and
(b) the original mismatch is only partly neutralised by the application of this Subdivision and equivalent provisions of applicable *foreign hybrid mismatch rules. 832-635(2)
This Subdivision applies as if:
(a) the offshore deducting entity had made a payment in the next *foreign tax period; and
(b) the payment gave rise to an *offshore hybrid mismatch (the residual mismatch ); and
(c) the amount of the residual mismatch was the amount of the original mismatch that was not neutralised by the application of this Subdivision and equivalent provisions of applicable *foreign hybrid mismatch rules.
PART 4-5
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GENERAL
Division 832
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Hybrid mismatch rules
Subdivision 832-H
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Imported hybrid mismatch
Operative provisions
SECTION 832-635
Carry forward of residual offshore hybrid mismatches
832-635(1)
Subsection (2) applies if:
(a) a payment made in a particular *foreign tax period gave rise to an *offshore hybrid mismatch (the original mismatch ); and
(b) the original mismatch is only partly neutralised by the application of this Subdivision and equivalent provisions of applicable *foreign hybrid mismatch rules. 832-635(2)
This Subdivision applies as if:
(a) the offshore deducting entity had made a payment in the next *foreign tax period; and
(b) the payment gave rise to an *offshore hybrid mismatch (the residual mismatch ); and
(c) the amount of the residual mismatch was the amount of the original mismatch that was not neutralised by the application of this Subdivision and equivalent provisions of applicable *foreign hybrid mismatch rules.
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