[259CB Hybrid or otherwise impermissible deduction/non-inclusion mismatches and their extent]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259CB  Hybrid or otherwise impermissible deduction/non-inclusion mismatches and their extent]

[(1)     There is a “hybrid or otherwise impermissible deduction/non-inclusion mismatch”, in relation to a payment or quasi-payment, if either or both of case 1 or 2 applies.

(2)     Case 1 applies where—

(a)     the relevant deduction exceeds the sum of the amounts of ordinary income that, by reason of the payment or quasi-payment, arise to each payee for a permitted taxable period, and

(b)     all or part of that excess arises by reason of the terms, or any other feature, of the financial instrument.

[(3)     So far as the excess arises—

(a)     by reason of a relevant debt relief provision, or

(b)     in relevant debt relief circumstances,

it is to be taken not to arise by reason of the terms, or any other feature, of the financial instrument (whether or not it would have arisen by reason of the terms, or any other feature, of the financial instrument regardless).]

[(3A)     So far as the excess arises by reason of an interest distribution designation, it is to be taken not to arise by reason of the terms, or any other feature, of the financial instrument (whether or not it would

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