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Taxation (International and Other Provisions) Act 2010 section 259ED
Counteraction where a payee is within the charge to corporation tax
Section 259ED provides the secondary counteraction for hybrid payer deduction/non-inclusion mismatches, applying where the payee (the party receiving the payment) is within the charge to UK corporation tax and the primary counteraction (which restricts the payer's deduction) has not been applied or has not fully resolved the mismatch.
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