On November 24, 2017 the Australian Government released exposure draft legislation that seeks to implement the recommendations of the 2015 OECD report regarding BEPS Action 2 “Neutralising the Effects of Hybrid Mismatch Arrangements” for public consultation. The consultation period will run until December 22, 2017.

Responses can be sent via e-mail to the following e-mail address: This email address is being protected from spambots. You need JavaScript enabled to view it..

Or via normal mail to:

The Manager
Base Erosion and Profit Shifting Unit
Corporate Income Tax Division
Revenue Group
The Treasury
Langton Crescent


In the 2016-17 and 2017-18 Budgets the Australian Government announced 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 Australian Government is now seeking the interested parties’ 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 neutralize any hybrid double non-taxation benefits by either denying deductions or including amounts in assessable income.


Click here to be forwarded to exposure draft legislation as published on November 24, 2017 by the Australian Government.


Click here to the Explanatory Memorandum, which was also released on November 24, 2017.


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