F1PART 6AHybrid and other mismatches
CHAPTER 8Multinational payee deduction/non-inclusion mismatches
Introduction
259HOverview 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, where the payer is within the charge to corporation tax, because a payee is multinational company.
2
The Chapter counteracts mismatches by altering the corporation tax treatment of the payer.
3
Section 259HA contains the conditions that must be met for this Chapter to apply.
4
Subsection (4) of that section defines “multinational company”, “parent jurisdiction” and “PE jurisdiction”.
5
Section 259HB defines “multinational payee deduction/non-inclusion mismatch” and provides how the amount of the mismatch is to be calculated.
6
Section 259HC contains provision that counteracts the mismatch.
7
See also—
a
section 259BB for the meaning of “payment”, “quasi-payment”, “payment period”, “relevant deduction”, “payer” and “payee”;
b
section 259BF for the meaning of “permanent establishment”.
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