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

[259HB  Multinational payee deduction/non-inclusion mismatches and their extent]

[(1)     There is a “multinational 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 multinational companies.

[(1A)     But there is no multinational 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

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