On 16 December 2021, the Australian Taxation Office (ATO) issued Practical Compliance Guideline 2021/5 on imported hybrid mismatch rule – ATO’s compliance approach (PCG 2021/5) relating to a practical administrative approach to the imported hybrid mismatch provisions in subdivision 832-H of the Income Tax Assessment Act 1997.
PCG 2021/5 will apply retroactively for income years beginning on or after 1 January 2019 for importing payments made under a structured arrangement and 1 January 2020 for all other imported hybrid mismatch arrangements.
