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On 16 December 2021, the Australian Taxation Office (ATO) finalised Practical Compliance Guideline PCG 2021/5 (PCG) which sets out the expectations regarding the Commissioner's assessment of risk in connection with the imported hybrid mismatch rules, including the Commissioner's approach to reviewing whether a taxpayer has undertaken reasonable enquiries in relation to the rules for non-structured arrangements. This PCG is relevant to any Australian taxpayer that makes any cross-border related party payments (including interest, royalties, management fees and purchases of raw materials and trading stock).

Reporting obligations for all multinational companies (MNC) with operations in Australia in relation to the hybrid mismatch rules are extensive and are expected to be expanded for the 2022 tax year.