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s 830-1

Standard application

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Chapter 4International aspects of income tax
Part 4-5General
Division 830Application of the foreign hybrid rules

830-1 Standard application

Foreign hybrids

(1)

Division 830 of the Income Tax Assessment Act 1997 applies to assessments for the 2003‑2004 income year, and each later income year, of a taxpayer who will as a result be a partner in an entity that is a foreign hybrid in relation to that income year.

CFCs that are, directly or indirectly, partners in foreign hybrids

(2)

Division 830 of the Income Tax Assessment Act 1997 applies for the purpose of working out the attributable income, in relation to an attributable taxpayer, for:

(a)

the statutory accounting period that starts on 1 July 2003 or on the day on which, as a result of an election under subsection 319(2) of the Income Tax Assessment Act 1936, the statutory accounting period that would otherwise start on 1 July 2003 starts; and

(b)

each later statutory accounting period;

of a CFC that:

(c)

will as a result be a partner in an entity that is a foreign hybrid in relation to that statutory accounting period; or

(d)

has, directly or indirectly through one or more other entities, an interest in another entity that will, as a result, be a foreign hybrid in relation to that statutory accounting period.

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Section 830-1 — Standard application — Income Tax (Transitional Provisions) Act 1997 (Commonwealth) — Barrister AI