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

[259GD  Counteraction where the investor is within the charge to corporation tax]

[(1)     This section applies in relation to an investor in a hybrid payee where—

(a)     the investor 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)     neither section 259GC nor any equivalent provision under the law of a territory outside the United Kingdom applies, or

(ii)     a provision of the law of a territory outside the United Kingdom that is equivalent to section 259GC applies, but does not fully counteract the hybrid payee deduction/non-inclusion mismatch mentioned in section 259GA(5).

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

(a)

Powered by Lexis+®
 

Popular documents

LEXISNEXIS

Common law offence of false imprisonment

Common law offence of false imprisonmentThe offence of false imprisonmentFalse imprisonment is a common law offence but it is more common as a civil action in tort (see Practice Note: False imprisonment).It is triable only on indictment. It may be classified in class 2A, 2B or 3 in accordance with

LEXISNEXIS

Strict liability

Strict liabilityStrict liabilityWhen an offence does not require proof of a mental element it is an offence of strict liability. There are some common law offences of strict liability (eg public nuisance, outraging public decency and contempt) most though are statutory, arising often under

LEXISNEXIS

Arbitration agreements—definition, purpose and interpretation

Arbitration agreements—definition, purpose and interpretationThis Practice Note considers the nature and scope of arbitration agreements with a particular focus on arbitration agreements pursuant to the law of England and Wales, although it also discusses the concept from an international

LEXISNEXIS

Negligence—key elements to establish a negligence claim

Negligence—key elements to establish a negligence claimNegligence—what are the key ingredients to establish a claim in negligence?For liability in negligence to be founded, four key ingredients must be present:•duty of care•breach of that duty•damage (which is caused by the breach)•foreseeability of