Commonwealth Consolidated Acts

INCOME TAX ASSESSMENT ACT 1997 - SECT 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.

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