Taxation (International and Other Provisions) Act 2010 section 259KE

Limit on reduction under section 259KC

Section 259KE places a cap on the amount by which a taxpayer's deduction can be reduced when dealing with imported mismatch payments under the hybrid mismatch rules.

• This section applies when a taxpayer's deduction for an imported mismatch payment is being reduced under the hybrid mismatch rules
• The reduction in the deduction is subject to a maximum limit
• The cap is calculated by reference to what the mismatch would have been if the mismatch payment had equalled the imported mismatch payment
• This prevents the deduction reduction from exceeding the actual economic mismatch involved