Taxation (International and Other Provisions) Act 2010 section 259CD

Counteraction where the payer is within the charge to corporation tax for the payment period

Section 259CD sets out the primary counteraction for hybrid mismatch arrangements involving financial instruments, where the payer is a UK corporation tax payer — the payer's tax deduction is reduced by the amount of the mismatch.

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.