INTM557040 - Hybrids: hybrid entity double deduction mismatches (Chapter 9): conditions to be satisfied: condition B

Condition B of s259IA requires that

• the investor is within the charge to corporation tax in the UK for the investor deduction period, or
• the hybrid entity is within the charge to corporation tax in the UK for the hybrid entity deduction period

The investor deduction period is the taxable period of the investor in which the amount is deducted for the purposes of calculating taxable profits of that investor.

The hybrid entity deduction period is the taxable period of the hybrid entity in which the amount is deducted for the purposes of calculating taxable profits of the entity.

The taxable period is defined at s259NF. Broadly speaking, the taxable period is the period for which the specific tax is charged.