ATO Consulting on Draft Taxation Determination Regarding Hybrid Mismatch Rules

The Australian Taxation Office (ATO) has published draft Taxation Determination (TD) 2024/D1 - Income tax: hybrid mismatch rules - application of certain aspects of the 'liable entity' and 'hybrid payer' definitions. Comments on the draft Determination are due by 19 April.

---

What this draft Determination is about

1. Division 832 of the Income Tax Assessment Act 1997 (ITAA 1997) contains hybrid mismatch rules. In broad terms, these rules are designed to prevent multinational corporation…