F1PART 6AHybrid and other mismatches

CHAPTER 7Hybrid payee deduction/non-inclusion mismatches

Counteraction

259GCCounteraction where the payer is within the charge to corporation tax for the payment period

(1)

This section applies where the payer is within the charge to corporation tax for the payment period.

(2)

For corporation tax purposes, the relevant deduction that may be deducted from the payer's income for the payment period is reduced by an amount equal to the hybrid payee deduction/non-inclusion mismatch mentioned in section 259GA(5).