Hybrid mismatch targeted integrity rule: draft ruling

KPMG's Peter Madden, Fabian Fedele & Bevis Field discuss a Law Companion Ruling dealing with particular aspects of the targeted integrity rule.

The Australian Taxation Office (ATO) has released Draft Law Companion Ruling LCR 2019/D1, which sets out its view on particular aspects of the targeted integrity rule within the hybrid mismatch rules in Division 832 of the ITAA 1997 for public comment. It is proposed that this draft Ruling will be finalised as a public ruling, effective from 1 January 2019.Background The targeted integrity rule in Subdivision 832-J aims to prevent offshore multinationals from circumventing the hybrid mismatch...

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Authors: Peter Madden, Fabian Fedele,

Published Date: 13 May 2019