On 16 December 2021, the Australian Taxation Office (ATO) released in final Practical Compliance Guideline PCG 2021/5 Imported hybrid mismatch rule – ATO’s compliance approach (PCG 2021/5). PCG 2021/5 provides long-awaited final guidance on the imported mismatch rule, replacing the Draft Practical Compliance Guideline (Draft PCG).
Broadly the imported hybrid mismatch rule operates to disallow a deduction for a payment if the income from such a payment is set-off, directly or indirectly, against a…