Join Danielle Sherwin in this ten-part Tax Chats (International Tax 101) series as she provides concise and practical updates on various international tax matters.

Episode 9 delivers some critical insights into Hybrid Mismatch Rules.

If you have any questions in relation to international tax and transfer pricing, please contact Danielle by emailing [email protected].

Key takeaways:

1. Avoiding Blind Intercompany Deductions: In the complex world of international tax, it’s crucial not to claim intercompany deductions without robust supporting analysis. Document your rationale, understand the implications, and ensure compliance with local regulations.

2. Leveraging Group-Level Work: Consider synergies within your multinational group. What work has already been done at the group level? Can you leverage existing documentation or analyses to support your Australian tax position? Collaboration across teams can yield valuable insights.

3. US Parented Taxpayers, Take Note: If your organisation is US parented, pay extra attention. Common US tax elections can significantly impact hybrid mismatch provisions. Stay informed about cross-border implications and explore strategies to optimise your tax position.

Danielle Sherwin

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Danielle is a Partner in the Tax Services division in the Sydney office. 

Danielle specialises in international tax, with a focus on transfer pricing and international tax. She assists her clients with their international tax planning and transfer pricing needs, ranging from Significant Global Entities (SGE) assessment, Country-by-Country (CBC) reporting, transfer pricing planning and advisory to transfer pricing compliance and documentation. 

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