Overview of Chapter
259K
(1) This Chapter contains provision denying deductions in connection with payments or quasi-payments that are made under, or in connection with, imported mismatch arrangements where the payer is within the charge to corporation tax for the payment period. (2) Section 259KA contains the conditions that must be met for this Chapter to apply and defines “imported mismatch payment” and “imported mismatch arrangement”. (3) Section 259KB defines “dual territory double deduction”, “excessive PE deduction” and “PE jurisdiction”. (4) Section 259KC contains provision for denying some or all of a relevant deduction in relation to an imported mismatch payment. (4A) Section 259KD provides for relief where an amount is deducted from dual inclusion income. (4B) Section 259KE sets a limit on reductions under section 259KC. (4C) Section 259KF contains provision for cases also falling within Part 4 (transfer pricing). (5) See also section 259BB for the meaning of “payment”, “quasi-payment”, “relevant deduction”, “payment period” and “payer”.