The approach to complying with Australia’s hybrid mismatch rules has evolved since their introduction as multinational groups continue to grapple with these complex, untested, rules that require detailed knowledge of transactions across a global group and analysis of how both Australian and foreign tax rules apply.
Taxpayer understanding of what is needed to document compliance has also evolved, particularly following publication of the ATO’s evidentiary expectations for the imported hybrid mismatch rule in PCG 2021/5 and now as the ATO includes this area as a standing item in its combined assurance reviews.
This session explores how the ATO’s expectations and taxpayer understanding of the hybrid mismatch rules has evolved and what multinational groups should be thinking about to ensure they are ready for ATO review.