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

[Counteraction]

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

[(1)     This section applies in relation to the investor in the hybrid entity where the investor is within the charge to corporation tax for the investor deduction period.

(2)     For corporation tax purposes, the hybrid entity double deduction amount may not be deducted from the investor's income for the investor deduction period unless it is deducted from dual inclusion income of the investor for that period.

(3)     So much of the hybrid entity double deduction amount (if any) as, by virtue of subsection (2), cannot be deducted from the investor's income for the investor deduction period—

(a)     is carried forward to subsequent accounting periods of the investor, and

(b)     for corporation tax purposes, may be deducted from dual inclusion income of the investor for any such period (and not from any other income),

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