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

[259ED  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)     no provision under the law of a territory outside the United Kingdom that is equivalent to section 259EC applies, or

(ii)     such a provision does apply, but does not fully counteract the hybrid payer deduction/non-inclusion mismatch mentioned in section 259EA(5).

(2)     A provision of the law of a territory outside the United Kingdom that is equivalent to section 259EC does not fully counteract that mismatch if (and only if)—

(a)     the amount of the relevant deduction that the provision prevents from being deducted from income of the hybrid payer, for the payment period, other than dual inclusion income, is less than the amount of the mismatch, and

(b)

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