Income Tax (Transitional Provisions) Act 1997

Subdivision 832‑H (Imported hybrid mismatch) of the Income Tax Assessment Act 1997 applies to assessments for income years starting on or after 1 January 2019.

However, in applying Subdivision 832‑H to assessments for income years starting before 1 January 2020, items 2 and 3 of the table in subsection 832‑615(2) are to be disregarded.

Despite subsection (1), Subdivision 832‑H does not apply in relation to an offshore hybrid mismatch unless a deduction component of the mismatch arose in a foreign tax period that ends in an income year starting on or after 1 January 2019.

In determining whether subsection (3) is satisfied in relation to an offshore hybrid mismatch, disregard section 832‑635 of the Income Tax Assessment Act 1997.