On 3 July 2024, the Australian Taxation Office (ATO) issued Taxation Determination (TD) 2024/4 - Income tax: hybrid mismatch rules - application of certain aspects of the 'liable entity' and 'hybrid payer' definitions. TD 2024/4 applies both before and after its date of issue. However, the Determination will not apply to taxpayers to the extent that it conflicts with the terms of settlement of a dispute agreed to before the date of issue of the Determination.
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What this Determination i…