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

Priority

Section 259NEA establishes which rules take precedence when both the hybrid mismatch rules and the corporate interest restriction rules could apply to the same situation.

• When applying the hybrid mismatch rules in this Part of the Act, the corporate interest restriction rules are to be ignored.
• This means the hybrid mismatch rules are given priority over the corporate interest restriction rules.
• The corporate interest restriction rules in Part 10 of the Act are treated as having no effect for hybrid mismatch purposes.
• This prevents conflicts between the two sets of rules and ensures a consistent order of application.