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

Application of Chapter 9

Section 259MC provides a de minimis exclusion from the hybrid entity double deduction mismatch rules in Chapter 9 where an investor holds its interest through a transparent fund and that interest accounts for less than 10% of the potential double deduction amount.

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.