Treasury Laws Amendment – hybrid mismatch rules
The Treasury Laws Amendment (Tax Integrity and Other Measures No.2) Bill 2018 was passed by the Federal Parliament in June. The ASF met with the ATO to discuss our request for formal ATO guidance on the scope of the ‘structured arrangements’ rule of the new Act.
With assistance from members, the ASF provided commentary and examples of typical securitisation structures to assist the ATO draft guidelines the industry can work with to clearly determine what is or what is not a ‘structured arrangement’ under the new foreign hybrid rules and thereby allow tax advisers to provide less qualified opinions to issuers.
In December 2018 the ATO released its draft structured arrangement guidance for comment:
- LCR 2018/D9 OECD hybrid mismatch rules - concept of structured arrangement
- PCG 2018/D9 OECD hybrid mismatch rules - concept of structured arrangement
The ASF with the assistance of its members has now prepared a response to the ATO's draft guidance as follows:
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