Australia Issues Final Practical Compliance Guideline and Law Companion Ruling on Structured Arrangements in Relation to Hybrid Mismatch Rules

The Australian Taxation Office has issued Practical Compliance Guideline (PCG) 2019/6 and Law Companion Ruling (LCR) 2019/3, which concern the concept of structure arrangements in relation to Australia's new hybrid mismatch rules. The hybrid mismatch rules were introduced as part of legislation enacted in August 2018 and generally apply to arrangements involving related parties and structured…
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