Part 12 Interaction with Part 4 of TIOPA 2010

Part 12 Interaction with Part 4 of TIOPA 2010

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TIOPA 2010 is amended as follows.

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In Part 4 (transfer pricing), after section 192 insert—

“192A Provision for cases within Part 6A

(1)     Subsection (2) applies to the extent that—

(a)     there is an amount to be deducted in respect of a payment by the issuing company under the security,

(b)     that amount is required to be reduced (whether or not to nil) under section 147(3) or (5),

(c)     the guarantor company

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