On 3 July 2024, the Australian Taxation Office (ATO) issued Taxation Determination (TD) 2024/4 - Income tax: hybrid mismatch rules - application of certain aspects of the 'liable entity' and 'hybrid payer' definitions. TD 2024/4 applies both before and after its date of issue. However, the Determination will not apply to taxpayers to the extent that it conflicts with the terms of settlement of a dispute agreed to before the date of issue of the Determination. --- What this Determination is about 1. Division 832 of the Income Tax Assessment Act 1997 (ITAA 1997) contains hybrid mismatch rules. In broad...