Australian tax guidance clarifies new hybrid mismatch law

The Australian Taxation Office today issued a draft law companion ruling (LCR 2018/D9) describing the government’s view of what the phrases ‘structured arrangement’ and ‘party to the structured arrangement’ mean in the context of hybrid mismatch rules

Australia’s hybrid mismatch rules, adopted in August 2018, are based on OECD recommendations. The rules are designed to prevent multinational groups from exploiting mismatches in two countries’ tax laws.