Implementing the OECD Hybrid Mismatch Rules

This consultation process has now been completed. Submissions available
Consultation Type
Exposure Draft

Key Documents

The Government announced in the 2016-17 and 2017-18 Budgets that it would implement the Organisation for Economic Co operation and Development's (OECD) rules aimed at eliminating double non-taxation benefits from hybrid mismatch arrangements which exploit differences in the tax treatment of an entity or instrument under the laws of two or more tax jurisdictions.

The Government is seeking the community’s views on the exposure draft legislation that targets instances where tax is either deferred or not paid at all from the use of such arrangements. The draft legislation will apply broadly to related parties, members of a control group and structured arrangements and is designed to neutralise any hybrid double non-taxation benefits by either denying deductions or including amounts in assessable income.


14 submissions were received for this consultation.

Deloitte - pdf 210.69 KB
EY - pdf 663.5 KB
KPMG - pdf 117.61 KB
Pitcher Partners - pdf 574.4 KB
PwC - pdf 149.17 KB
Tax Justice Network - pdf 252.06 KB