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

»Ê¹ÚÌåÓýapp 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.

»Ê¹ÚÌåÓýapp 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.

»Ê¹ÚÌåÓýapp taxable period is defined at s259NF. Broadly speaking, the taxable period is the period for which the specific tax is charged.