[259DD Interpretation of section 259DC]

[259DD  Interpretation of section 259DC]

[(1)     This section has effect for the purposes of section 259DC.

(2)     A taxable period of a payee is “permitted” in relation to an amount of ordinary income that arises as a result of the payment or quasi-payment if—

(a)     the period begins before the end of 12 months after the end of the payment period, or

[(b)     the period begins at a later time and it is just and reasonable for the amount of ordinary income to arise for the period (rather than an earlier one)].

(3)     An amount of ordinary income of a payee, for a permitted taxable period, is “under taxed” if the highest rate at which tax is charged on the taxable profits of the payee in which the amount is included, taking into account on a just and reasonable basis the effect of any credit

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