[259CE Counteraction where a payee is within the charge to corporation tax]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259CE  Counteraction where a payee is within the charge to corporation tax]

[(1)     This section applies in relation to a payee where—

(a)     the payee is within the charge to corporation tax for an accounting period some or all of which falls within the payment period, and

(b)     it is reasonable to suppose that—

(i)     neither section 259CD nor any equivalent provision under the law of a territory outside the United Kingdom applies, or

(ii)     a provision of the law of a territory outside the United Kingdom that is equivalent to section 259CD applies, but does not fully counteract the hybrid or otherwise impermissible deduction/non-inclusion mismatch mentioned in section 259CA(4).

(2)     A provision of the

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