107 “Effective tax mismatch outcome”
Finance Act 2015 (2015 c 11) | Legislation

107  “Effective tax mismatch outcome”

(1)     This section applies for the purposes of sections 80 and 86(2).

(2)     In this section “the first party” and “the second party” mean—

(a)     where this section applies for the purposes of section 80, C and P (within the meaning of section 80) respectively, and

(b)     where this section applies for the purposes of section 86(2), the foreign company and A (within the meaning of section 86) respectively.

(3)     The material provision results in an effective tax mismatch outcome as between the first party and the second party for an accounting period of the first party if—

(a)     in that accounting period, in relation to a relevant tax, it results in one or both of—

(i)     expenses of the first party for which a deduction has been taken into account in computing the amount of the relevant tax payable by the first party, or

(ii)     a reduction in the income of the first party which would otherwise have been taken into account in computing the amount

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