ATO finalises guidance on hybrid payer arrangements

The guidance sets out the Commissioner’s final view on the operation of the ‘liable entity’ and ‘hybrid payer’ concepts which impact the application of Australia’s hybrid mismatch rules, as outlined by Peter Oliver, Denis Larkin, Jennifer Ta and Fabian Fedele.

The Australian Taxation Office (ATO) published Tax Determination TD 2024/4 (the Final TD) on 3 July 2024, setting out the Commissioner’s final view on the operation of the ‘liable entity’ and ‘hybrid payer’ concepts which impact the application of Australia’s hybrid mismatch rules in Division 832 of the Income Tax Assessment Act 1997. TD 2024/4 is a finalisation (with only minor changes) of TD 2024/D1 (Draft TD) which was previously released in March 2024 for consultation. We discussed our ...

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Authors: Peter Oliver, Denis Larkin,

Published Date: 05 July 2024