On January 13, 2021, the Australian tax authority published Law Companion Ruling 2021/1, providing the Commissioner's view of particular aspects of the law in relation to the hybrid mismatch targeted integrity rule.
The hybrid mismatch targeted integrity rule – contained in Subdivision 832-J of the Income Tax Assessment Act, 1997 – was legislated as part of the package of measures making up Australia's hybrid mismatch rules.
This Ruling also covers the amendments to the targeted integrity rule (and other provisions impacted by the rule's hypothetical operation), contained in Parts 1 and 3 of Schedule 1 to the Treasury Laws Amendment (2020 Measures No.2) Act, 2020.
The Ruling is effective from January 1, 2019.
See Law Companion Ruling 2021/1