[61W Prevention of double charge to tax and allowance of certain deductions]

[61W  Prevention of double charge to tax and allowance of certain deductions]

[(1)     Subsection (2) applies where—

(a)     a person (“the payee”) receives a payment or benefit (“the end-of-line remuneration”) from another person (“the paying intermediary”),

(b)     the end-of-line remuneration can reasonably be taken to represent remuneration for services of the payee to [another person (“the client”)],

(c)     a payment (“the deemed payment”) has been treated by section 61N(3) as made to the payee,

(d)     the underlying chain payment can reasonably be taken to be for the same services of the payee to [the client], and

(e)     the recipient of the underlying chain payment has (whether

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