ATO guidance on hybrid mismatch rules – a timely reminder

This update serves as a timely reminder of the broad application of the hybrid rules and the multiple factors taxpayers need to consider as they work through tax compliance cycles and prepare for ATO engagements, as discussed by Peter Oliver, Fabian Fedele, Rosie El Khoury and Josefina Martinez.

The Australian Taxation Office (ATO) website was updated on 25 January 2024 to provide taxpayers with a single point of reference for its current guidance in respect of the hybrid mismatch rules (the hybrid rules). The ATO update provides a useful compilation and summary of all legislation, amendments and supporting material previously issued (including law companion rulings, taxation determinations and practical compliance guidelines) on the interpretation and application of the h...

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Authors: Peter Oliver, Fabian Fedele,

Published Date: 12 March 2024