Miscellaneous 2019

Anti-hybrids: The current state of play

Source: The Tax Specialist Journal Article

Published Date: 1 Aug 2019

 

The anti-hybrid rules introduced in Australia in August 2018 started to take effect for entities with a 30 June year end on 1 July 2019. The recent start date means that taxpayers have started to focus on how the new rules will apply to them and the ATO has started to develop guidance products on the provisions. The provisions are complex and potentially broad in their application and will result in changes to the Australian tax treatment of many instruments and arrangements. This article provides a general overview of the rules and their development, before considering a series of practical examples exploring how the rules may affect a range of common instruments and structures.

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