[259ICA Deemed dual inclusion income for the purposes of section 259IC]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259ICA  Deemed dual inclusion income for the purposes of section 259IC]

[(1)     For the purposes of section 259IC(10)(b) the reference to ordinary income of an investor in the hybrid entity for a permitted taxable period for the purposes of any tax charged under the law of an investor jurisdiction is taken to include a reference to an amount that meets the following requirements.

(2)     The requirements are that—

(a)     the amount may not be deducted under the law of any territory from the income of any person for the purposes of calculating taxable profits for a relevant taxable period;

(b)     in the

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