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Taxation (International and Other Provisions) Act 2010 section 259EB
Hybrid payer deduction/non-inclusion mismatches and their extent
Section 259EB defines what constitutes a hybrid payer deduction/non-inclusion mismatch in relation to a payment or quasi-payment, sets out how to measure the extent of such a mismatch, and provides rules for determining whether the mismatch arises because of the hybrid nature of the payer.
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