[259KD Deductions from dual inclusion income]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259KD  Deductions from dual inclusion income]

[(1)     If—

(a)     section 259KA(6)(a) applies as a result of any of sub-paragraphs (iii) to (vii), or

(b)     section 259KA(6)(b) applies,

a reduction under section 259KC is not to exceed the relevant net amount.

(2)     For the purposes of this section “the relevant net amount” means—

(a)     if section 259KA(6)(a)(iii), (iv), (v) or (vi) applies, the amount which, if Chapter 5, 7, 8 or 9 applied to the tax treatment of any person in respect of the mismatch payment, could not be deducted from that person's income under that Chapter (ignoring the effect of any of the carry-forward provisions),

(b)     if section 259KA(6)(a)(vii) applies, the amount by which the dual territory double deduction of the company mentioned in section 259KB(2) for a deduction

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