Australia Issues Final Practical Compliance Guideline on Restructuring to Comply with Hybrid Mismatch Rules

The Australian Taxation Office (ATO) has issued Practical Compliance Guideline (PCG) 2018/7, which sets out the ATO's compliance approach with respect to Part IVA (general anti-avoidance rule) of the Income Tax Assessment Act 1936 and certain restructures that comply with the objectives of the new Hybrid Mismatch rules. The Hybrid Mismatch rules, which are in line with BEPS Action 2, were approved in August 2018 and generally apply from 1 January 2019 ({News-2018-08-21/A/2-previous coverage}…