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Anti-hybrids: The current state of play
Published on 01 Aug 19 by "THE TAX SPECIALIST" JOURNAL ARTICLE
The anti-hybrid rules introduced in Australia in August 2018 started to take effect for entities with a 30 June year end on 1 July 2019. The recent start date means that taxpayers have started to focus on how the new rules will apply to them and 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 article provides a general overview of the rules and their development, before considering a series of practical examples exploring how the rules may affect a range of common instruments and structures.
Author profiles
Andrew Hirst CTA
Andrew is a Partner and Head of Financial Services at Greenwoods & Herbert Smith Freehills. Andrew advises on a range of corporate and banking-related tax issues with a particular focus on financial and international transactions. Andrew has worked with Treasury and the ATO on various areas of tax reform that impact the financial services industry. - Current at 16 November 2021
Ryan Leslie ATI
Ryan is a Partner in the Melbourne office of Herbert Smith Freehills. Ryan has more than 10 years’ 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 the infrastructure and energy sectors. Ryan specialises in advising on mergers and acquisitions, internal restructures, and disputes. - Current at 30 November 2022
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