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Taxation (International and Other Provisions) Act 2010 section 259JD
Counteraction where mismatch arises because of a relevant multinational and is not counteracted in the parent jurisdiction
Section 259JD restricts the use of dual territory double deductions where they arise because a company is a relevant multinational, the UK is the permanent establishment (PE) jurisdiction, and the parent jurisdiction has not applied its own equivalent anti-hybrid rules.
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