INTM552090 | Hybrids: hybrid transfers (Chapter 4): conditions to be satisfied: condition C

Condition C at s259DA(4) requires that either

• the payer must be within the charge to UK corporation tax for a relevant payment period, or

• a payee must be within the charge to UK corporation tax for an accounting period that falls wholly or partly within a relevant payment period

The relevant payment period is the taxable period of the payer in which an amount may be deducted for a payment or quasi-payment.