The Australian Taxation Office has published draft Practical Compliance Guideline (PCG) 2018/D9 and draft Law Companion Ruling (LCR) 2018/D9, which concern the concept of structure arrangements in relation to Australia's new hybrid mismatch rules. The hybrid mismatch rules were introduced as part of legislation enacted in August 2018 and generally apply to arrangements involving related parties and structured arrangements involving related or unrelated parties for income years starting on o…