Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

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  

832-540(1)  
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.

Note:

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

832-540(2)  
The amount of the *offshore hybrid mismatch is the *neutralising amount for the *deducting hybrid mismatch.


 

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