[259G Overview of Chapter]

[Chapter 7
Hybrid Payee Deduction/Non-Inclusion Mismatches]

[Introduction]

[259G  Overview of Chapter]

[(1)     This Chapter contains provision that counteracts deduction/non-inclusion mismatches that it is reasonable to suppose would otherwise arise from payments or quasi-payments because a payee is a hybrid entity.

(2)     The Chapter counteracts mismatches by—

(a)     altering the corporation tax treatment of the payer for the payment period,

(b)     treating

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