On 29 January 2026, the Department of Finance released two packages of draft legislative proposals for public comment. The proposals implement certain measures announced in the 2025 federal budget, as well as other previously announced measures and new technical amendments, including the much-anticipated second package of hybrid mismatch arrangement rules.
In this Tax Alert, we provide an overview of certain proposals outlined in the second package of hybrid mismatch rules, which is intended to implement the recommendations of the report under Action 2 of the OECD/G20 Base Erosion and Profit Shifting project, titled Neutralising the Effects of Hybrid Mismatch Arrangements.