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

[259IC  Counteraction where the hybrid entity is within the charge to corporation tax]

[(1)     This section applies where—

(a)     the hybrid entity is within the charge to corporation tax for the hybrid entity deduction period,

(b)     it is reasonable to suppose that—

(i)     no provision under the law of an investor jurisdiction that is equivalent to section 259IB applies, or

(ii)     such a provision does apply, but the hybrid entity double deduction amount exceeds the amount that, under that provision, cannot be deducted from income, for the investor deduction period, other than dual inclusion income of the hybrid entity for the hybrid entity deduction period, and

(c)     the secondary counteraction condition is met.

(2)     The secondary counteraction condition is met if—

(a)     the hybrid entity and any investor in it are in the same control group (see section 259NB) at any time in—

(i)     the hybrid entity deduction period, or

(ii)     the investor deduction period, or

(b)     there is an arrangement, to which the hybrid entity or any investor in it is party, that is a structured arrangement (within the meaning given by section 259IA(7) and (8)).

(3)     In this section “the restricted deduction” means—

(a)

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