Textual Amendments
F1Pt. 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
(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”.]