SCHEDULES

SCHEDULE 7U.K.Hybrid and other mismatches

PART 8 U.K.Chapters 9 and 10: carry forward of illegitimate overseas deduction

18(1)Part 6A of TIOPA is amended as follows.U.K.

(2)In section 259IC (counteraction where hybrid entity is within charge to corporation tax), in subsection (8), after “person” insert “ other than an investor in the hybrid entity ”.

(3)In section 259JB (counteraction where mismatch arises because of a dual resident company), in subsection (6), after “person” insert “ other than the company ”.

(4)In section 259JD (counteraction where mismatch arises because of a relevant multinational and is not counteracted in the parent jurisdiction), in subsection (6), after “person” insert “ other than the company ”.