[259JD Counteraction where mismatch arises because of a relevant multinational and is not counteracted in the parent jurisdiction]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259JD  Counteraction where mismatch arises because of a relevant multinational and is not counteracted in the parent jurisdiction]

[(1)     This section applies where—

(a)     the dual territory double deduction amount arises as a result of the company being a relevant multinational company,

(b)     the United Kingdom is the PE jurisdiction, and

(c)     it is reasonable to suppose that no provision of the law of the parent jurisdiction that is equivalent to section 259JC applies.

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

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

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

(b)     for corporation tax purposes, may be deducted from dual inclusion income of the

Powered by Lexis+®
 

Popular documents

LEXISNEXIS

Enforcing a warrant of control

Enforcing a warrant of controlThis Practice Note has been produced by enforcement specialists, The Sheriffs Office. It guides users through the process of enforcing a warrant of control obtained from the County Court as a method of enforcing a money judgment; whereby the judgment creditor takes

LEXISNEXIS

Novation—why and how to novate a contract

Novation—why and how to novate a contractThere may be times when, rather than assigning the benefit of an agreement to a third party, the original parties wish instead to end their obligations to each other under that agreement and, in effect, recreate it, with the third party stepping into the

LEXISNEXIS

How is the National Employment Savings Trust (NEST) different from a typical occupational pension scheme?

How is the National Employment Savings Trust (NEST) different from a typical occupational pension scheme?In this Practice Note, references to the National Employment Savings Trust (NEST) Order are to the National Employment Savings Trust Order 2010, SI 2010/917 (NEST Order) applicable from 25 May

LEXISNEXIS

Option agreements—the need for a long-stop date

Call options are frequently used by developers to secure a right to buy land if planning permission is obtained. Taking an option provides the developer with time to make and pursue a planning application before having to commit to paying for the land. The developer's initial outlay will be limited