Income Tax Assessment Act 1997
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Hide history noteSECTION 832-390 When a reverse hybrid mismatch is an offshore hybrid mismatch 832-390(1)
A * reverse hybrid mismatch is an offshore hybrid mismatch if:
(a) the * deduction component of the mismatch is a * foreign income tax deduction; and
(b) the country in which the foreign income tax deduction arose does not have * foreign hybrid mismatch rules that correspond to this Subdivision.
Note:
An offshore hybrid mismatch might give rise to an imported hybrid mismatch: see Subdivision 832-H .
832-390(2)
The amount of the * offshore hybrid mismatch is the amount of the * reverse hybrid mismatch.
[ CCH Note: S 832-290(2) will be amended by No 79 of 2020, s 3 and Sch 1 item 44, by substituting " unless, in the country in which the * foreign income tax deduction arose, the mismatch is covered by * foreign hybrid mismatch rules that correspond to this Subdivision, or by a law that has substantially the same effect as foreign hybrid mismatch rules that correspond to this Subdivision " for all the words after " required " , effective 1 October 2020 and applicable to assessments for income years starting on or after 1 January 2020. ]
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