INTM555110 - INTM555110 - Hybrids: hybrid payee (Chapter 7): counteraction: payer

The counteraction where the payer is within the charge to UK corporation tax is set out at s259GC.

The payer is denied a deduction for the payment period for the amount of the hybrid payee deduction/non-inclusion mismatch.

The payment period is the taxable period of the payer in which an amount may be deducted for the relevant payment or quasi-payment.