Section 259C | Overview of Chapter ^F1

(1)This Chapter contains provision that counteracts hybrid or otherwise impermissible deduction/non-inclusion mismatches that it is reasonable to suppose would otherwise arise from payments or quasi-payments under, or in connection with, financial instruments.

(2)The Chapter counteracts mismatches where the payer or a payee is within the charge to corporation tax and does so by altering the corporation tax treatment of the payer or a payee.

(3)Section 259CA contains the conditions that must be met for this Chapter to apply.

(4)Section 259CB defines “hybrid or otherwise impermissible deduction/non-inclusion mismatch” and provides how the amount of the mismatch is to be calculated.

(5)Section 259CC contains definitions of certain terms used in section 259CB.

(6)Section 259CD contains provision that counteracts the mismatch where the payer is within the charge to corporation tax for the payment period.

(7)Section 259CE contains provision that counteracts the mismatch where a payee is within the charge to corporation tax and neither section 259CD nor any equivalent provision under the law of a territory outside the United Kingdom fully counteracts the mismatch.

(8)See also—

(a)section 259BB for the meaning of “payment”, “quasi-payment”, “payment period”, “relevant deduction”, “payer” and “payee”, and

(b)section 259N for the meaning of “financial instrument”.