Commonwealth Consolidated Acts

INCOME TAX ASSESSMENT ACT 1997 - SECT 832.540

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

  (a)   the only * deduction components of the mismatch are * foreign income tax deductions; and

  (b)   the mismatch is not covered by * foreign hybrid mismatch rules that correspond to this Subdivision, or by a law that has substantially the same effect as foreign hybrid mismatch rules that correspond to this Subdivision, in any country in which a foreign income tax deduction arose.

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 * neutralising amount for the * deducting hybrid mismatch.