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

[259GB  Hybrid payee deduction/non-inclusion mismatches and their extent]

[(1)     There is a “hybrid payee 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 one or more payees being hybrid entities.

[(1A)     But there is no hybrid payee 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 extent of the hybrid payee deduction/non-inclusion mismatch is equal to the excess that arises as mentioned in subsection (1)(b).

[(2A)     No excess is to be taken to arise by reason of a hybrid payee being a hybrid entity for the purposes of subsection (1)(b)

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