Imported mismatch rule: ATO releases draft practical compliance guideline

As detailed by Denis Larkin, Fabian Fedele, Tammy Eccles & Bevis Field, the breadth of the imported hybrid mismatch rule requires Australian taxpayers to understand arrangements outside of their domestic business.

The Australian Taxation Office (ATO) has released for consultation draft Practical Compliance Guideline 2021/D3: Imported mismatch rule – ATO’s compliance approach in relation to the application of the imported mismatch provisions in Subdivision 832-H of the Income Tax Assessment Act 1997. Imported mismatch provisions Broadly, the policy intent of the imported hybrid mismatch rule is to prevent taxpayers from making payments that fund an offshore hybrid mismatch which provides an overall ta...

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Authors: Denis Larkin, Fabian Fedele,

Published Date: 22 April 2021