24 Hybrid and other mismatches
Finance (No 2) Act 2017 (2017 c 32) | Legislation

24  Hybrid and other mismatches

(1)     Part 6A of TIOPA 2010 (hybrid and other mismatches) is amended as follows.

(2)     In section 259B(3) (local taxes), for “is not outside the scope of subsection (2) by reason only that” substitute “is outside the scope of subsection (2) if”.

(3)     In section 259CC(2) (hybrid and other mismatches from financial instruments: meaning of “permitted” taxable period of a payee), for paragraph (b) substitute—

“(b)     the period begins at a later time and it is just and reasonable for the amount of ordinary income to arise for the period (rather than an earlier one).”

(4)     In section 259DD(2) (hybrid transfer deduction/non-inclusion mismatches: meaning of “permitted” taxable period of a payee), for paragraph (b) substitute—

“(b)     the period begins at a later time and it is just and reasonable for the amount of ordinary income to arise for the period (rather than an earlier one).”

(5)     In section 259EB (hybrid payer deduction/non-inclusion mismatches and their extent), after subsection (1) insert—

“(1A)     But there is no hybrid payer deduction/non-inclusion mismatch so far as the relevant deduction is—

(a)     a debit in respect of amortisation that is brought into account under section 729 or 731

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