Hybrid Mismatch and Multinational Group Financing Integrity Rules - 25 June 2018


Hybrid Mismatch and Multinational Group Financing Integrity Rules - 25 June 2018

Tax insights

On 21 June 2018, the Australian Taxation Office (ATO) released draft Practical Compliance Guideline PCG 2018/D4 (draft PCG) setting out the ATO’s proposed compliance approach with respect to the potential application of Australia’s general anti-avoidance rule (Part IVA) to restructures of hybrid mismatch arrangements.

The draft PCG follows the introduction into Australian Parliament on 24 May 2018 of measures addressing hybrid mismatch arrangements, together with a targeted integrity rule, as part of the Treasury Laws Amendment (Tax Integrity and Other Measures No. 2) Bill 2018. In this Tax Insights we outline the key takeaways from the draft PCG and the proposed measures in the Bill.

Published: June 2018

Hybrid Mismatch and Multinational Group Financing Integrity Rules - 25 June 2018
  • Contact us
  • Submit RFP
  • Our solutions

    Progress your business growth and development

    Take a look at the products and services we offer.

    Tax services

    Business tax, International tax, Transfer pricing, Tax management consulting, Mergers and acquisitions – tax, Research and development and government incentives, Deloitte Private, Indirect tax, Global employer services and Business Process Solutions

    Indirect tax

    Indirect tax is becoming many governments' preferred method of revenue raising. It’s more critical than ever to manage indirect tcompliance and cash flows. Deloitte’s indirect tax experts understand the nuances of regulations, the importance of industry knowledge and the growing role of technology.

    Tax management consulting

    With consulting, technology and outsourcing experience, Deloitte TMC helps businesses meet the challenges of multi-jurisdictional tax operations, including compliance, reporting and risk management for direct and indirect taxes. 

  • Our latest reports and thought leadership
Did you find this useful?