[259KA Circumstances in which the Chapter applies]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[Application of Chapter]

[259KA  Circumstances in which the Chapter applies]

[(1)     This Chapter applies if conditions A to G are met.

(2)     Condition A is that a payment or quasi-payment (“the imported mismatch payment”) is made under, or in connection with, an arrangement (“the imported mismatch arrangement”).

(3)     Condition B is that, in relation to the imported mismatch payment, the payer (“P”) is within the charge to corporation tax for the payment period.

(4)     Condition C is that the imported mismatch arrangement is one of a series of arrangements.

(5)     A “series of arrangements” means a number of arrangements that are each entered into (whether or not one after the other) in pursuance of, or in relation to, another arrangement (“the over-arching arrangement”).

(6)     Condition D is that—

(a)     under an arrangement in the series other than the imported mismatch arrangement, there is a payment or quasi-payment (“the mismatch payment”) in relation to which it is reasonable to

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