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Demystifying Australia’s hybrid mismatch law paper


This paper covers: 

  • operation of the hybrid mismatch measures
  • common concepts underlying the hybrid mismatch measures.

Author profiles

Andrew Nelson CTA
Andrew has been a partner with EY since 2008 and has 23 years experience providing international and corporate taxation advisory services to Australian outbound and multinational clients investing into Australia. Commencing his early career with a resource industry and US inbound focus, Andrew now specialises in providing international tax support for cross border transactions across a broad industry base. Recent transactions include cross border M&A and financing projects in the asset management, private equity, consumer products, technology, media and entertainment and oil and gas and mining industries. From 2014 to 2017 Andrew was based in New York as the leader of the Australian team in the Global Tax Desk network, a role that involved immersion in the OECD BEPS developments impacting on global corporate M&A and financing. Now based back in Perth Australia, Andrew holds a Masters of International Taxation from the University of Melbourne and holds a senior leadership role within the EY Oceania international Tax practice. - Current at 25 June 2018
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Britta Perry
Britta Perry is a senior manager in EY’s international tax practice. She has recently returned from a secondment on EY’s Australian tax desk based in New York where she was advising multinational clients across a variety of industries on Australian tax matters including a number of OECD BEPS related developments. Britta’s focus is on inbound and outbound transactions, with particular experience in the application of hybrid mismatch law and diverted profits tax in the context of cross-border financing. - Current at 03 July 2018


This was presented at International Masterclass 2018 .

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