INTM558050 - Hybrids: dual territory double deduction (Chapter 10): counteraction: contents

If conditions A and B are satisfied the counteractions set out at s259JB, s259JC and s259JD apply to counter the mismatch in the UK.

The counteraction varies depending on whether the company is dual resident or a relevant multinational company, and whether the UK is the parent or PE jurisdiction.

1. INTM558060

   Dual resident company
2. INTM558070

   Relevant multinational and the UK is the parent jurisdiction
3. INTM558080

   Relevant multinational and the UK is the PE jurisdiction