(1) However, if there is a secondary response country in relation to the * deducting hybrid mismatch (see section 832 - 555), and that country is Australia, section 832 - 530 does not apply in relation to the * deducting hybrid mismatch unless:
(a) the secondary response is required (see subsection (2)); and
(b) subsection (3) or (4) applies.
When secondary response is required
(2) For the purposes of paragraph (1)(a), the secondary response is required unless:
(a) a * liable entity in respect of the income or profits of the * deducting hybrid satisfies the residency test in subsection 832 - 555(9) in the primary response country; and
(b) in the primary response country, the mismatch is 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.
(3) This subsection applies if the following entities are in the same * Division 832 control group:
(b) if one or more entities other than the deducting hybrid is a * liable entity in respect of the income or profits of the deducting hybrid in a deducting country--each such liable entity.
Note: For the meaning of Division 832 control group , see section 832 - 205.
(4) This subsection applies if the payment is made under a * structured arrangement.
Note 1: For the meaning of structured arrangement , see section 832 - 210.
Note 2: If the deduction is a non - payment deduction, see also
subsection 832 - 110(5).