Document ID: chunk:federal_register_of_legislation:C2025C00029:section:115:p19
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 115 (pt 19/40)
Character Range: 6551081–6554106

References to foreign income tax in section 830‑10 or 830‑15 do not include certain taxes
Subdivision 830‑B—Extension of normal partnership provisions to foreign hybrid companies
830‑20 Treatment of company as a partnership
830‑25 Partners are the shareholders in the company
830‑30 Individual interest of a partner in net income etc. equals percentage of notional distribution of company's profits
830‑35 Partner's interest in assets
830‑40 Control and disposal of share in partnership income
Subdivision 830‑C—Special rules applicable while an entity is a foreign hybrid
830‑45 Partner's revenue and net capital losses from foreign hybrid not to exceed partner's loss exposure amount
830‑50 Deduction etc. where partner's foreign hybrid revenue loss amount and foreign hybrid net capital loss amount are less than partner's loss exposure amount
830‑55 Meaning of foreign hybrid net capital loss amount
830‑60 Meaning of loss exposure amount
830‑65 Meaning of outstanding foreign hybrid revenue loss amount
830‑70 Meaning of outstanding foreign hybrid net capital loss amount
830‑75 Extended meaning of subject to foreign tax
Subdivision 830‑D—Special rules applicable when an entity becomes or ceases to be a foreign hybrid
830‑80 Setting the tax cost of partners' interests in the assets of an entity that becomes a foreign hybrid
830‑85 Setting the tax cost of assets of an entity when it ceases to be a foreign hybrid
830‑90 What the expression tax cost is set means
830‑95 What the expression tax cost setting amount means
830‑100 What the expression tax cost means
830‑105 What the expression asset‑based income tax regime means
830‑110 No disposal of assets etc. on entity becoming or ceasing to be a foreign hybrid
830‑115 Tax losses cannot be transferred to a foreign hybrid
830‑120 End of CFC's last statutory accounting period
830‑125 How long interest in asset, or asset, held
Division 832—Hybrid mismatch rules
Guide to Division 832
832‑1 What this Division is about
              Subdivision 832‑A—Preliminary
              Guide to Subdivision 832‑A
832‑5 What this Subdivision is about
Operative provisions
832‑10 Entitlement to receive payment
832‑15 Entitlement to receive non‑cash benefits
832‑20 Losses that arise from payments or parts of payments
832‑25 Recipients and payers of a payment
832‑30 How this Division applies to entities
832‑35 Single entity rule otherwise not disregarded
832‑40 Schemes outside Australia
832‑45 Relationship between this Division and other charging provisions in this Act
832‑50 Relationship between this Division and Division 820
832‑55 Division does not affect foreign residence rules
832‑60 Valuation of trading stock affected by hybrid mismatch rules
Subdivision 832‑B—Concepts relating to mismatches
Guide to Subdivision 832‑B
832‑100 What this Subdivision is about
Operative provisions
832‑105 When a payment gives rise to a deduction/non‑inclusion mismatch
832‑110 When a payment gives rise to a deduction/deduction mismatch
832‑115 Disregard effect of Division in