F1PART 6AHybrid and other mismatches
CHAPTER 5Hybrid payer deduction/non-inclusion mismatches
Introduction
259EOverview of Chapter
1
This Chapter contains provision that counteracts deduction/non-inclusion mismatches that it is reasonable to suppose would otherwise arise from payments or quasi-payments because the payer is a hybrid entity.
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 259EA contains the conditions that must be met for this Chapter to apply.
4
Section 259EB defines “hybrid payer deduction/non-inclusion mismatch” and provides how the amount of the mismatch is to be calculated.
5
Section 259EC contains provision that counteracts the mismatch where the payer is within the charge to corporation tax for the payment period.
6
Section 259ED contains provision that counteracts the mismatch where a payee is within the charge to corporation tax and the mismatch is not fully counteracted by provision under the law of a territory outside the United Kingdom that is equivalent to section 259EC.
7
See also—
a
section 259BB for the meaning of “payment”, “quasi-payment”, “payment period”, “relevant deduction”, “payer” and “payee”, and
b
section 259BE for the meaning of “hybrid entity”, “investor” and “investor jurisdiction”.
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