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

Definitions

Section 259NF provides a glossary of the key terms used throughout Part 6A of the Act, which deals with hybrid mismatch arrangements.

• The section defines core terms such as "arrangement", "payment", "payer", "payee", and "relevant deduction" that underpin the hybrid mismatch rules.
• It explains entity-related concepts including "hybrid entity", "investor", "permanent establishment", "control group", and "related" persons.
• It sets out the meaning of tax-related terms such as "tax", "taxable period", "taxable profits", "ordinary income", "CFC charge", and "foreign CFC charge".
• It clarifies that "arrangement" is defined very broadly, covering any agreement, understanding, scheme, transaction, or series of transactions, whether or not legally enforceable.

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