Commonwealth Consolidated Acts

INCOME TAX ASSESSMENT ACT 1997 - SECT 832.195

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

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

  (b)   no amount becomes * subject to Australian income tax as a result of the application of section   832 - 185 in relation to the mismatch; and

  (c)   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.

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 * hybrid financial instrument mismatch.