F1PART 6AHybrid and other mismatches
CHAPTER 3Hybrid and other mismatches from financial instruments
Introduction
259COverview of Chapter
1
This Chapter contains provision that counteracts hybrid or otherwise impermissible deduction/non-inclusion mismatches that it is reasonable to suppose would otherwise arise from payments or quasi-payments under, or in connection with, financial instruments.
2
The Chapter counteracts mismatches where the payer or a payee is within the charge to corporation tax and does so by altering the corporation tax treatment of the payer or a payee.
3
Section 259CA contains the conditions that must be met for this Chapter to apply.
4
Section 259CB defines “hybrid or otherwise impermissible deduction/non-inclusion mismatch” and provides how the amount of the mismatch is to be calculated.
5
Section 259CC contains definitions of certain terms used in section 259CB.
6
Section 259CD contains provision that counteracts the mismatch where the payer is within the charge to corporation tax for the payment period.
7
Section 259CE contains provision that counteracts the mismatch where a payee is within the charge to corporation tax and neither section 259CD nor any equivalent provision under the law of a territory outside the United Kingdom fully counteracts the mismatch.
8
See also—
a
section 259BB for the meaning of “payment”, “quasi-payment”, “payment period”, “relevant deduction”, “payer” and “payee”, and
b
section 259N for the meaning of “financial instrument”.
Pt. 6A inserted (with effect in accordance with Sch. 10 paras. 18-21 of the amending Act) by Finance Act 2016 (c. 24), Sch. 10 para. 1