[259GE Counteraction where a hybrid payee is an LLP]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259GE  Counteraction where a hybrid payee is an LLP]

[(1)     This section applies in relation to a hybrid payee where the hybrid payee is a limited liability partnership and it is reasonable to suppose that—

(a)     none of the following provisions applies—

(i)     section 259GC;

(ii)     section 259GD;

(iii)     any provision under the law of a territory outside the United Kingdom that is equivalent to either of those sections, or

(b)     one or more of those provisions apply, but the hybrid payee deduction/non-inclusion mismatch mentioned in section 259GA(5) is not fully counteracted.

(2)     The mismatch is not fully counteracted if (and only if), after the application of such of those provisions as apply—

(a)     the relevant deduction is not reduced by the full amount of the mismatch,

(b)

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