Commonwealth Consolidated Acts

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INCOME TAX ASSESSMENT ACT 1997 - SECT 832.605

What this Subdivision is about

This Subdivision neutralises an imported hybrid mismatch. This mismatch is an integrity rule that applies when one or more entities are interposed between a hybrid mismatch and a country that has hybrid mismatch rules.

Identifying an imported hybrid mismatch involves testing whether a hybrid mismatch involving 2 foreign countries has been "imported" into Australia by a deduction. If so, there are priority rules that allocate the neutralisation of the mismatch between countries that have hybrid mismatch rules.

Table of sections

Operative provisions

832 - 610   Deduction not allowable

832 - 615   When a payment gives rise to an imported hybrid mismatch

832 - 620   Hybrid mismatch

832 - 625   Meaning of importing payment

832 - 630   Working out the amount of the imported hybrid mismatch

832 - 635   Carry forward of residual offshore hybrid mismatches



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