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Hybrid Mismatch Rules – US GILTI rules do not correspond to Australia’s CFC rules - 30 June 2022

Tax insights


On 29 June 2022 the Australian Taxation Office (ATO) released its final determination (TD 2022/9, the Determination) in relation to whether section 951A of the US Internal Revenue Code (the US GILTI rules) correspond to section 456 or 457 of the Income Tax Assessment Act 1936 (Australia’s CFC rules) for the purpose of subsection 832-30(5) of the Income Tax Assessment 1997 (Australia’s hybrid mismatch rules).


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