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.
Sounds like you? Lets talk TP and Hybrid Mismatch for Australia.
If you're an Australian company currently claiming tax deductions for cross-border payments then you MUST consider the imported mismatch
If your business is engaged in international dealings with related parties, and has more than $2 million of related-party dealings, you are required to complete an international dealings schedule (IDS) and lodge it with your income tax return for that year.
Multinational Anti-Avoidance Law (MAAL) is an anti-avoidance measure created to combat tax avoidance by multinationals using certain
transfer pricing arrangements or structures to avoid the attribution of profit to a permanent establishment in Australia.