WEBINAR: Hybrid Mismatch Rules in Australia

EventsWEBINAR: Hybrid Mismatch Rules in Australia

Hybrid Mismatch Rules in Australia

8 September 2021


If you're an Australian company currently claiming tax deductions for cross-border payments then you MUST consider the imported mismatch rule.

The hybrid mismatch rules, introduced in 2018, are some of the most complex rules for taxpayers to apply. Very broadly, they typically apply where there is a cross-border payment which gives rise to a deduction/non-inclusion or double deduction outcome due to the tax system of two countries treating an arrangement or entity differently.

Most of the rules apply where that mismatch directly involves Australia. For example, a payment made by an Australian entity is deductible in Australia and not taxed overseas, or is deductible in Australia and also in another country. The international dealings schedule has been expanded to include a section on the Hybrid mismatch rules. The ATO recently set out its expectations in draft Practical Compliance Guideline 2021/D3 (PCG).

Sounds like you? Lets talk TP and Hybrid Mismatch for Australia.


In this webinar we will cover:

  1. What is Hybrid Mismatch?
  2. Who does it apply to?
  3. What if your cross-border payment is subject to Hybrid Mismatch?
  4. Are you at risk?
  5. ATO Recommendations


DATE 8 September 2021
TIME 4:00 - 4:45pm

We are the experts in hybrid mismatch and other complex transfer pricing and tax rules in Australia. We look forward to sharing a practical and interactive webinar with you.



Transfer Pricing Solutions founder Shannon Smit spent 11 years working with a Big 4 in Melbourne, Amsterdam, Prague and New York, before returning to Melbourne in 2005. During 2005-2006 Shannon noticed the increased recruitment of in-house transfer pricing specialists to American tax teams as transfer pricing controversy increased around the world.

Shannon started to identify an opportunity as many Australian companies were also facing these increased transfer needs, but did not have a need or funding for a permanent transfer pricing team member, and other options available to them to fulfil this role were quite costly.

In early 2007 Shannon left the Big 4 firm to start Transfer Pricing Solutions.

Shannon has specialized in transfer pricing since 1998. Shannon is a Chartered Accountant, Registered Tax Agent and holds her Masters in International Tax Law and is on the Australian Governments Board of Taxation Working Group as an expert panel member for the Review of Tax Impediments Facing Small Business. Her position has been renewed annually for the past four years.


Hong Chuan Tan has over eight years of experience in transfer pricing and GST. Before joining Transfer Pricing Solutions, Hong Chuan was a Transfer Pricing Manager in BDO Malaysia. He played a key role in pioneering and developing the transfer pricing practice in Malaysia.

He specialises in the area of transfer pricing where he manages a portfolio of clients comprising companies from a broad range of industries such as mining; electrical and electronics; plastic products; construction and property development; hotels; real estate; oil and gas amongst others. He has prepared transfer pricing documentation (Master File and Local File) for the Asia Pacific region, in particular Australia, Malaysia, Singapore and the Philippines.

He possesses experience in working with leading brands with the primary focus to exceed the expectations on clients’ service delivery while ensuring optimum brand impact. He is able to provide effective and resourceful information on the transfer pricing related problems, provide recommendations for the client’s business and process improvements.


Cavin Tai is a transfer pricing specialist with over nine years of experience in advising multinational companies in Australia, Asia, and the USA.

Cavin has spent the first two years of his career as a senior analyst in another Professional Service Transfer Pricing team in Malaysia where he develops extensive knowledge in analytics. With this experience, Cavin has helped develop, tailor and apply comprehensive analytic solutions to assist clients across the Asia region (including Malaysia, Singapore, Japan and Thailand) with resolving transfer pricing disputes.

In Australia, Cavin has worked on a broad range of complex transfer pricing controversy and planning projects where he helped his clients obtain most favourable results by adopting practical, commercial strategies that partner with viable transfer pricing solutions.

During his career, Cavin has advised multinational both in Australia and overseas on various transfer pricing issues including planning, development and implementation of global transfer pricing policy, transfer pricing compliance (Documentation & Country-by-Country reporting) and controversy (Audit Defence).

Malaysian Institute of Tax Professionals
Singapore Chartered Tax Professionals
Boutique Firm of the Year 2022
Fast Growing Firm of The Year WINNER Badge 2020
Singapore TP Firm - 2020
Malaysia TP Newcome - 2019
Singapore TP Firm - 2019
AU TP firm of the Year Asia Tax Awards FINALIST 2019
AU TP firm of the Year Asia Tax Awards FINALIST 2018
Singapore TP Firm - 2018
Asia TP Newcomer of the Year Asia Tax Awards Winner 2017
Asia TP Leader of the Year/Shannon Smit Asia Tax Awards Winner 2017
AU TP firm of the Year Asia Tax Awards FINALIST 2017
Asia Tax Awards 2016
Aust Accounting Awards 2015_PARTNER OF THE YEAR
Aust Accounting Awards BOUTIQUE FIRM OF THE YEAR 2014
Thompson Routers 2015
Thompson Routers_TP TEAM OF THE YEAR_ 2014 FINALIST
Thompson Routers 2013