Commonwealth Consolidated Acts

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INCOME TAX ASSESSMENT ACT 1997 - SECT 832.390

When a reverse hybrid mismatch is an offshore hybrid mismatch

  (1)   A * reverse hybrid mismatch is an offshore hybrid mismatch if:

  (a)   the * deduction component of the mismatch is a * foreign income tax deduction; and

  (b)   the country in which the foreign income tax deduction arose does not have * foreign hybrid mismatch rules that correspond to this Subdivision.

Note:   An offshore hybrid mismatch might give rise to an imported hybrid mismatch: see Subdivision   832 - H.

  (2)   The amount of the * offshore hybrid mismatch is the amount of the * reverse hybrid mismatch.


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