Foreign Hybrid Mismatch Rules
Issues covered include: anti-hybrid mismatch, guideance products, ATO, foreign hybrid mismatch rules
Description
Australia’s new hybrid mismatch regime now applies and is highly complex. All multinational groups will need to ascertain whether it applies to them, and what to do if it does. Ensure you have a solid knowledge of the new rules and best practice advice for your clients.
Foreign Hybrid Mismatch Rules: How They Apply
With the introduction of the new anti-hybrid mismatch rules, taxpayers have started to focus on how the new rules will apply to them. At the same time, the ATO has started to develop guidance products on the provisions. The provisions are complex and potentially broad in their application and will result in changes to the Australian tax treatment of many instruments and arrangements. This session will consider a series of practical examples exploring how the rules may affect a range of instruments and structures.
Presented by Andrew Hirst, Partner and Ryan Leslie, Partner, Greenwoods & Herbert Smith Freehills
Location Streamed From: Sydney
Accreditation
Attend and Earn 1 CPD Hour
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Presenters
Andrew Hirst, Partner at Greenwoods & Herbert Smith Freehills. Andrew is widely regarded as one of the leading banking/financial services tax advisers in Australia. Andrew was involved in the consultations in relation to the development and introduction of the hybrid mismatch rules and has advised a number of clients on their application over the course of the last two years
Ryan Leslie is a Partner at Greenwoods & Herbert Smith Freehills Pty Limited in Melbourne. Ryan joined Greenwoods in 2012 and has experience in advising on the income tax aspects of a broad range of corporate, international and trust tax taxation matters, with a particular focus on mergers and acquisitions, transaction structuring, internal restructures and disputes.