[259DA Circumstances in which the Chapter applies]

[Application of Chapter]

[259DA  Circumstances in which the Chapter applies]

[(1)     This Chapter applies if conditions A to E are met.

(2)     Condition A is that there is a hybrid transfer arrangement in relation to an underlying instrument (see section 259DB).

(3)     Condition B is that a payment or quasi-payment is made under or in connection with—

(a)     the hybrid transfer arrangement, or

(b)     the underlying instrument.

(4)     Condition C is that—

(a)     the payer is within the charge to corporation tax for the

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