[259A Overview of Part]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[Part 6A Hybrid and Other Mismatches]

[Chapter 1
Introduction]

[259A  Overview of Part]

[(1)     This Part has effect for the purposes of counteracting certain cases that it is reasonable to suppose would otherwise give rise to—

(a)     a deduction/non-inclusion mismatch, or

(b)     a double deduction mismatch.

(2)     A deduction/non-inclusion mismatch arises where an amount is deductible from a person's income—

(a)     without a corresponding amount of ordinary income arising to another person, or

(b)     where an amount of ordinary income does arise to a person but is under taxed.

(3)     A double deduction mismatch arises where—

(a)     an amount is deductible from more than one person's income, or

(b)     an amount is deductible from a person's income for the purposes of more than one tax.

(4)     The cases with which this Part is concerned involve—

(a)     payments or quasi-payments under or in connection with financial instruments or repos, stock lending arrangements or other transfers of financial instruments,

(b)     hybrid entities,

(c)     companies with permanent establishments, or

(d)     dual resident companies.

(5)     This Part counteracts mismatches that would otherwise arise by making certain

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