The Australian government has released Terms of Reference in preparation for anti-hybrid legislation, expected to be announced 12 May, 2016 in the federal budget. Effective dates may be set as of 1 July, 2016 or 1 January, 2017 for calendar year taxpayers.
Specific rules are under consideration, including:
- Objectives for eliminating double non-taxation
- Economic costs for Australia
- Taxpayer compliance costs
- Interactions of domestic legislation, tax treaties and new anti-hybrid rules, expected to be announced by the OECD in October 2015.
A PwC Tax Insight summary is included for reference:
Australia, recently following the lead of the UK for diverted profits tax initiatives, has shown its proactive stance for adoption of the new OECD guidelines.
It is important to note that Australia will wait for the final OECD guidelines to pass matching legislation. This legislative trend, and steps to initiate BEPS proposals quickly, will be a trend to watch for the rest of world countries.