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

Overview of Chapter

Section 259ZM provides an overview of the chapter that allows surplus dual inclusion income to be shared between companies within the same group.

• This chapter enables a company with more dual inclusion income than it needs (a "DII surplus") to allocate that surplus to another company in the same group that has a shortfall (a "DII shortfall").
• Section 259ZMA sets out the conditions that must be met before this chapter applies, and defines what constitutes a DII surplus and a DII shortfall.
• Sections 259ZMB to 259ZMD explain how the unused part of one company's DII surplus can be treated as dual inclusion income of another group company, matching it against that other company's unused DII shortfall.
• Section 259ZME defines when companies are considered to be in the same group for the purposes of this chapter.