INTM552090 - Hybrids: hybrid transfers (Chapter 4): conditions to be satisfied: condition C
Condition C at s259DA(4) requires that either
- the payer must be within the charge to UK corporation tax for a relevant payment period, or
- a payee must be within the charge to UK corporation tax for an accounting period that falls wholly or partly within a relevant payment period
The relevant payment period is the taxable period of the payer in which an amount may be deducted for a payment or quasi-payment.