26 Amendments of section 259GB of TIOPA 2010
Finance Act 2022 (2022 c 3) | Legislation

26  Amendments of section 259GB of TIOPA 2010

(1)     Section 259GB of TIOPA 2010 (hybrid payee deduction/non-inclusion mismatches and their extent) is amended as follows.

(2)     In subsection (4A)—

(a)     in the words before paragraph (a), after “partnership” insert “or a relevant transparent entity”;

(b)     in paragraph (a), after “partnership” insert “, or a member of the entity,”;

(c)     in paragraph (b)—

(i)     in sub-paragraph (i), after “partnership” insert “or entity”;

(ii)     in sub-paragraph (ii), after “partner”, in each place it occurs, insert “or member”.

(3)     After that subsection insert—

“(4AA)     Subsection (4AB) applies in relation to a payment or quasi-payment if—

(a)     one or more of the payees is a partnership or a relevant transparent entity,

(b)     there is a territory under the law of which an amount of ordinary income would arise, or would potentially arise, to a hybrid entity as a result of the circumstances giving rise to the relevant deduction if the entity

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