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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Counteraction

  • Section 259GC Counteraction where the payer is within the charge to corporation tax for the payment period
  • Section 259GD Counteraction where the investor is within the charge to corporation tax
  • Section 259GE Counteraction where a hybrid payee is an LLP
  1. Counteraction
  2. Counteraction where the payer is within the charge to corporation tax for the payment period

Section 259GC | Counteraction where the payer is within the charge to corporation tax for the payment period

From legislation.gov.uk

(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).

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