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22 June 2018

Australia issues draft tax guidance on restructures of hybrid mismatch arrangements and effect of tax avoidance rules

The Australian Taxation Office (ATO) released draft Practical Compliance Guideline Part IVA of the Income Tax Assessment Act 1936 and restructures of hybrid mismatch arrangements (PCG 2018/D4) on June 21. The hybrid mismatch rules contained in Treasury Laws Amendment (Tax Integrity and Other Measures No.2) Bill 20181 represent the Australian implementation of the Organisation of Economic Co-operation and Development (OECD) Action 2 (Neutralizing the Effect of Hybrid Mismatch Arrangements).

A Global Tax Alert, attached below, provides additional details.

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Document ID: 2018-1278

 

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