Finance Act 2021 (c. 26)

SCHEDULES

SCHEDULE 7 U.K. Hybrid and other mismatches

PART 12 U.K. Interaction with Part 4 of TIOPA 2010

31 U.K. In Part 4 (transfer pricing), after section 192 insert—

“192A Provision for cases within Part 6A

(1) Subsection (2) applies to the extent that—

(a) there is an amount to be deducted in respect of a payment by the issuing company under the security,

(b) that amount is required to be reduced (whether or not to nil) under section 147(3) or (5),

(c) the guarantor company makes a claim under section 192(1) in respect of that reduction, and

(d) as regards the payment, provision in Part 6A would, but for the reduction, apply in relation to the tax treatment of the issuing company (“the relevant tax treatment”).

(2) The relevant tax treatment is to apply in relation to the guarantor company.”