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

Counteraction where a payee is within the charge to corporation tax

Section 259CE provides the secondary counteraction for hybrid mismatch arrangements involving financial instruments, requiring a payee within the charge to UK corporation tax to bring an amount into income where the payer's deduction has not been fully counteracted under the primary response rules.

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.