19 Hybrid and other mismatches: scope of Chapter 8 and “financial instrument”
Finance Act 2019 (2019 c 1) | Legislation

19  Hybrid and other mismatches: scope of Chapter 8 and “financial instrument”

(1)     Part 6A of TIOPA 2010 (hybrid and other mismatches) is amended as follows.

(2)     In section 259HA (circumstances in which Chapter 8 applies)—

(a)     for subsection (5) substitute—

“(5)     Condition C is that—

(a)     the payer is within the charge to corporation tax for the payment period, or

(b)     the multinational company—

(i)     is UK resident for the payment period, and

(ii)     under the law of the parent jurisdiction, is regarded as carrying on a business in the PE jurisdiction through a permanent establishment in that territory but, under the law of the PE jurisdiction, is not regarded as doing so.”, and

(b)

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