[259JC Counteraction where mismatch arises because of a relevant multinational and the UK is the parent jurisdiction]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259JC  Counteraction where mismatch arises because of a relevant multinational and the UK is the parent jurisdiction]

[(1)     This section applies where—

(a)     the dual territory double deduction amount arises by reason of the company being a relevant multinational company, and

(b)     the United Kingdom is the parent jurisdiction.

(2)     If some or all of the dual territory double deduction amount is (in substance) deducted (“the impermissible overseas deduction”), for the purposes of a tax under the law of a territory outside the United Kingdom, from the

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