SCHEDULES

SCHEDULE 7Hybrid and other mismatches

PART 7Financing cost of loan capital

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1

Chapter 6 of Part 6A of TIOPA 2010 (hybrid and other mismatches: deduction/non-inclusion mismatches relating to transfers by permanent establishments) is amended in accordance with sub-paragraph (2).

2

In section 259FA(4) (circumstances in which the Chapter applies), omit the “and” after paragraph (a) and after paragraph (b) insert

, and

c

is not in respect of the financing cost of loan capital which the permanent establishment is assumed to have by virtue of section 21(2) of CTA 2009 for the purpose of applying subsection (1) of that section (the separate enterprise principle).