Section 832 — Income Tax Assessment Act 1997 (Cth)

A “hybrid mismatch” arises if double non‑taxation results from the exploitation of differences in the tax treatment of an entity or financial instrument under the laws of 2 or more countries.

There is double non‑taxation if a deductible payment is not included in a tax base (this is called a deduction/non‑inclusion mismatch), or if a payment gives rise to 2 deductions (this is called a deduction/deduction mismatch). Disallowing a deduction, or including an amount in assessable income, “neutralises” this tax advantage.

Related sections

• s 815 — ‑1  What this Subdivision is about
• s 820 — ‑1  What this Division is about
• s 830 — ‑1  What this Division is about
• s 840 — ‑1  What this Division is about
• s 842 — ‑100  What this Subdivision is about
• s 855 — ‑1  What this Division is about

Research how courts apply s 832

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