In April 2019, Australian Taxation Office (ATO) released a draft Law Companion Ruling on the Organization for Economic Cooperation and Development (OECD) hybrid mismatch rules related to integrity rule. The ATO have now released draft LCR 2019/D1 for public consultation. This captures feedback from consultations to date, and the amendments to clarify the hybrid rules in Treasury Laws Amendment (2020 Measures No.2) Bill 2020 that were introduced into Parliament on 13 May 2020.
The draft ruling provides the Commissioner’s view on aspects of the law in relation to the hybrid mismatch targeted integrity rule in Subdivision 832-J of the Income Tax Assessment Act 1997. The draft ruling took effect from 1 January 2019.
As part of the process, ATO invites for comments on the additional content included in the updated draft guidance that covers the recently introduced amendments. The consultation period is open until 24 July 2020.