Almost six years after the enactment of the hybrid mismatch rules, application of the provisions is still challenging for taxpayers. There continues to be many unresolved interpretational issues and guidance from the ATO has been limited.
In this session, we discuss the key technical and compliance issues typically arising for multinationals in applying the hybrid mismatch rules. We will also share practical insights and issues we see arising for multinationals in responding to the ATO’s hybrid questions in reviews including in relation to potential problematic entity structures such as foreign hybrids.