INTM553050 | Hybrids: hybrid payer (Chapter 5): conditions to be satisfied: condition C

Condition C of s259EA TIOPA 2010 requires

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

• a payee to 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 in relation to a payment or quasi-payment.