On 20 November 2015, the Australian Board of Taxation issued a discussion paper on the implementation of rules to neutralize hybrid mismatch arrangements. The rules are in line with guidance developed as part of Action 2 of the OECD BEPS Project, which Australia is planning to implement in full. Action 2 includes recommendations to counter various hybrid arrangements that result in:
- Deduction / No Inclusion outcomes;
- Deduction / Deduction outcomes (double deduction); and
- Indirect Deduction …