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Part 4U.K.Transfer pricing

Modifications etc. (not altering text)

C1Pt. 4 excluded by 2010 c. 4, s. 938N (as inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 5 para. 2)

C4Pt. 4 excluded (with effect in accordance with s. 148 of the amending Act) by Finance Act 2012 (c. 14), s. 129(11) (with s. 147, Sch. 17)

CHAPTER 5U.K.Position of guarantor of affected person's liabilities under a security issued by the person

Modifications etc. (not altering text)

C5Pt. 4 Chs. 1 and 3-6 applied (1.4.2022 in relation to accounting periods beginning on or after that date) by Finance Act 2022 (c. 3), s. 51(1), Sch. 9 paras. 3, 4

[F1192AProvision for cases within Part 6AU.K.

(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.]

Textual Amendments

F1S. 192A inserted (with effect in accordance with Sch. 7 paras. 37-39 of the amending Act) by Finance Act 2021 (c. 26), Sch. 7 para. 31