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Taxation (International and Other Provisions) Act 2010

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Changes over time for: Section 259ID

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Version Superseded: 10/06/2021

Alternative versions:

Status:

Point in time view as at 15/09/2016. This version of this provision has been superseded. Help about Status

Changes to legislation:

There are currently no known outstanding effects for the Taxation (International and Other Provisions) Act 2010, Section 259ID. Help about Changes to Legislation

[F1259IDSection 259ID income for the purposes of section 259ICU.K.
This section has no associated Explanatory Notes

(1)This section applies where—

(a)section 259IC applies,

(b)the restricted deduction exceeds the dual inclusion income of the hybrid entity (if any) for the hybrid entity deduction period, and

(c)conditions A to D are met.

(2)Condition A is that—

(a)the investor in the hybrid entity makes a payment to the hybrid entity, and

(b)no amount is deductible, under the law of the investor jurisdiction, from the income of the investor in respect of the payment.

(3)Condition B is that, as a result of the payment, an amount of ordinary income arises to the hybrid entity for the hybrid entity deduction period.

(4)Condition C is that the payment is made in direct consequence of a payment made to the investor by a person (“the unrelated party”) who is not related (see section 259NC) to the investor or the hybrid entity.

(5)Condition D is that, as a result of the payment made by the unrelated party, an amount of ordinary income arises to the investor.

(6)For the purposes of section 259IC “section 259ID income” is an amount of income of the hybrid entity equal to the lesser of—

(a)the amount of the payment made by the investor to the hybrid entity, and

(b)the amount of the payment made by the unrelated party to the investor.]

Textual Amendments

F1S. 259ID inserted (15.9.2016 retrospectively) by Finance Act 2018 (c. 3), Sch. 7 paras. 14, 19(4)

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