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.
In this webinar we will discuss recent developments in international tax policy, and consider the impact for multinational companies to effectively manage their transfer pricing obligations. Get exclusive Q&A with our transfer pricing experts.
Country By Country (CbC) Reporting incorporates revised standards for transfer pricing documentation and a common template for SGEs to report income.
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).