Income Tax Assessment Act 1997



Division 832 - Hybrid mismatch rules  

Subdivision 832-G - Deducting hybrid mismatch  

Operative provisions

SECTION 832-540   When a deducting hybrid mismatch is an offshore hybrid mismatch  

A *deducting hybrid mismatch is an offshore hybrid mismatch if:

(a) the only *deduction components of the mismatch are *foreign income tax deductions; and

(b) the mismatch is not 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, in any country in which a foreign income tax deduction arose.


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

The amount of the *offshore hybrid mismatch is the *neutralising amount for the *deducting hybrid mismatch.


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