Commonwealth Consolidated Acts

INCOME TAX ASSESSMENT ACT 1997 - SECT 832.635

  (1)   Subsection   (2) applies if:

  (a)   a payment made in a particular * foreign tax period gave rise to an * offshore hybrid mismatch (the original mismatch ); and

  (b)   the original mismatch is only partly neutralised by the application of this Subdivision and equivalent provisions of applicable * foreign hybrid mismatch rules.

  (2)   This Subdivision applies as if:

  (a)   the offshore deducting entity had made a payment in the next * foreign tax period; and

  (b)   the payment gave rise to an * offshore hybrid mismatch (the residual mismatch ); and

  (c)   the amount of the residual mismatch was the amount of the original mismatch that was not neutralised by the application of this Subdivision and equivalent provisions of applicable * foreign hybrid mismatch rules.