Published Date: 23 Dec 2024
The Australian hybrid mismatch rules have been in place for over six years and as the implementation by other jurisdictions continues, the focus of the ATO on how taxpayers are applying and interpreting the rules has increased. The ATO’s evolving expectations have therefore resulted in the issuance of public advice and guidance, rulings and determinations, and increased scrutiny during risk and assurance reviews. This article aims to highlight the current tax issues and practicalities that are relevant to the application of the Australian hybrid mismatch rules, including its potential interaction with the implementation of the Pillar Two regime. The article also provides an overview of the ATO’s insights and findings as documented in its latest publications.
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