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

Circumstances in which the Chapter applies

Section 259FA sets out the three conditions (A to C) that must all be met for the hybrid mismatch rules in Chapter 6 to apply, targeting situations where a permanent establishment in the UK claims a tax deduction for a transfer to its overseas head office but little or no corresponding taxable income arises in the head office's jurisdiction.

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