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.
- AI tax research with linked legislation and Finance Act changes
- Commentary, official guidance, publications and training material
- Case law, appeals and tribunal decisions in one place
Taxation (International and Other Provisions) Act 2010 section 259GD
Counteraction where the investor is within the charge to corporation tax
Section 259GD sets out how a hybrid payee mismatch is counteracted by treating an amount as taxable income of the investor, where the investor is within the charge to UK corporation tax and the payer-side counteraction under section 259GC (or its overseas equivalent) has not fully addressed the mismatch.
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.