Section 259NF | Definitions

In this Part—^F1

“arrangement” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable);

“CFC” and “CFC charge” have the meaning given by section 259B(4);

“the Commissioners” means the Commissioners for Her Majesty's Revenue and Customs;

“control group” has the meaning given by section 259NB;

“financial instrument” has the meaning given by section 259N;

“foreign CFC” and “foreign CFC charge” have the meaning given by section 259B(4);

“hybrid entity” has the meaning given by section 259BE;

“investor”, in relation to a hybrid entity, has the meaning given by section 259BE(4);

“investor jurisdiction” has the meaning given by section 259BE(4);

“ordinary income” is to be read in accordance with sections 259BC and 259BD;

“payee”—

(a)in relation to a payment, has the meaning given by section 259BB(6)(a), and

(b)in relation to a quasi-payment, has the meaning given by section 259BB(6)(b);

“payee jurisdiction” has the meaning given by 259BB(9);

“payer”—

(a)in relation to a payment, has the meaning given by section 259BB(1)(a), and

(b)in relation to a quasi-payment, has the meaning given by section 259BB(2);

“payment” has the meaning given by section 259BB(1);

“payment period”—

(a)in relation to a payment, has the meaning given by section 259BB(1)(b), and

(b)in relation to a quasi-payment, has the meaning given by section 259BB(2);

“permanent establishment” has the meaning given by section 259BF;

“quasi-payment” has the meaning given by section 259BB(2) to (5);

“related” has the meaning given by section 259NC;

“relevant deduction”—

(a)in relation to a payment, has the meaning given by section 259BB(1)(b), and

(b)in relation to a quasi-payment, has the meaning given by section 259BB(2)(a);

“relevant investment fund” has the meaning given by section 259NA;

“tax” has the meaning given by section 259B;

“taxable period” means—

(a)in relation to corporation tax, an accounting period,

(b)in relation to income tax, a tax year,

(c)in relation to the CFC charge, a relevant corporation tax accounting period (within the meaning given by section 371BC(3)),

(d)in relation to a foreign CFC charge, a period (by whatever name known) that corresponds to a relevant corporation tax accounting period, and

(e)in relation to any other tax, a period for which the tax is charged;

“taxable profits” is to be read in accordance with sections 259BC(2) and 259BD(5).