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 832-465   When a branch hybrid mismatch is an offshore hybrid mismatch  

832-465(1)    
A * branch 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; and

(c) subsection 23AH(4A) of the Income Tax Assessment Act 1936 does not apply in relation to the branch hybrid mismatch.

Note:

An offshore hybrid mismatch might give rise to an imported hybrid mismatch: see Subdivision 832-H .

832-465(2)    
The amount of the * offshore hybrid mismatch is the amount of the * branch hybrid mismatch.