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ATO guidance on restructuring

ATO guidance on restructuring

KPMG’s Peter Madden, Fabian Fedele and Hanah Lewis discuss Practical Compliance Guideline: Part IVA of the Income Tax Assessment Act 1936 and restructures of hybrid mismatch arrangements.

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Peter Madden

National Leader, International Tax

KPMG Australia

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The Australian Taxation Office (ATO) has recently finalised Practical Compliance Guideline: Part IVA of the Income Tax Assessment Act 1936 and restructures of hybrid mismatch arrangements (“PCG 2018/7”).

The finalised guidance offers assistance to taxpayers who restructure out of hybrid arrangements, by broadly examining instances where an effort to redress a hybrid arrangement may result in the application of the anti-avoidance principle under Part IVA. In determining whether a restructure in this context will result in the application of Part IVA, PCG 2018/7 distinguishes between restructures that may be considered low or high risk.

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