Miscellaneous 2023

Hybrid mismatch rules: practical considerations

Source: Taxation In Australia Journal Article

Published Date: 1 Mar 2023

 

As Australia's response to the advice of the Organisation for Economic Co-operation and Development to address hybrid mismatches, the hybrid mismatch rules (HMRs) have been enacted in Div 832 of the Income Tax Assessment Act 1997 (Cth). These rules have increased compliance requirements, some of which are impractical and compromise the effectiveness of the rules, including: the accessibility of key tax information that Australian taxpayers have from structured party arrangements and related parties; the ability of accounting systems to trace transactions through interposed entities (and audit implications); and the knowledge gap that Australian tax professionals have on overseas tax laws (including understanding how the HMRs have been implemented differently across the globe) and the lack of Australian tax expert resourcing.

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Ramy Singh CTA

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Miscellaneous 2023

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