Hybrid Discretionary Trusts-Tax rulings

Here is a link to the taxpayer alert relating to hybrid trusts. If you currently have a hybrid trust arrangement, you can apply to the ATO for a private ruling.

The Tax Office considers that the arrangement outlined above may give rise to taxation issues that include: whether the general anti-avoidance provisions in Part IVA of the ITAA 1936 may apply to the arrangement, on the basis that its dominant purpose is to enable the taxpayer to obtain a tax benefit.

It's hard to argue with that.