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

[259EB  Hybrid payer deduction/non-inclusion mismatches and their extent]

[(1)     There is a “hybrid payer deduction/non-inclusion mismatch”, in relation to a payment or quasi-payment, if—

(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 hybrid payer being a hybrid entity.

[(1A)     But there is no hybrid payer deduction/non-inclusion mismatch so far as the relevant deduction is—

(a)     a debit in respect of amortisation that is brought into account under section 729 or 731 of CTA 2009 (writing down the capitalised cost of an intangible fixed asset), or

(b)     an amount that is deductible in respect of amortisation under a provision of the law of a territory outside the United Kingdom that is equivalent to either of those sections.]

(2)     The amount of the hybrid payer deduction/non-inclusion mismatch is equal

Powered by Lexis+®
 

Popular documents

LEXISNEXIS

Pension commencement lump sums (PCLSs)

Pension commencement lump sums (PCLSs)When a member of a pension scheme becomes entitled to receive their scheme benefits, they can usually take part as a tax-free lump sum. HMRC calls this a ‘pension commencement lump sum’ (PCLS). Taking a lump sum is usually at the option of the member who will

LEXISNEXIS

Repudiation

RepudiationThis Practice Note concerns repudiation and sets out what a repudiatory breach of contract means. It explains how a repudiatory breach goes to the core of the contract and the options or remedies available to an innocent party as a result of the other party’s repudiation, which include

LEXISNEXIS

Recklessness in criminal cases

Recklessness in criminal casesWhat is recklessness?In respect of some statutory offences and common law crimes the prosecution are required to prove a mental element of recklessness on the part of the defendant.Recklessness means unjustified risk taking on the part of the accused.Prior to the House

LEXISNEXIS

Escrow accounts and escrow agreements

Escrow accounts and escrow agreementsThis Practice Note examines why parties involved in a construction project may enter into an escrow agreement (or escrow deed) to set up an escrow account. It looks at the benefits of paying funds into escrow, how an escrow account operates and the provisions