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

Overview of Chapter 7: hybrid payee deduction/non-inclusion mismatches

Section 259G provides an overview of Chapter 7, which deals with counteracting tax mismatches that arise when a payment is made to a recipient (payee) that is a hybrid entity — that is, an entity treated differently for tax purposes in different jurisdictions, resulting in a deduction for the payer but no corresponding inclusion in the payee's taxable income.