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