ATO releases hybrid mismatch guidance dealing with US GILTI rules

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ATO releases hybrid mismatch guidance dealing with US GILTI rules - 25 November 2019

Tax Insights 

The ATO has released further draft guidance in relation to the Hybrid mismatch rules, as the first year of the application of the hybrid mismatch rules draws to a close. TD 2019/D12 outlines the Commissioner’s interpretative view that section 951A of the US Internal Revenue Code (the GILTI rule) does not correspond to the operative provisions of Australia’s controlled foreign company (CFC) rules (sections 456 or 457 of the Income Tax Assessment Act 1936 (ITAA36)) for the purposes of determining whether an amount is considered subject to foreign income tax by the hybrid mismatch rules.

ATO releases hybrid mismatch guidance dealing with US GILTI rules
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