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Taxation (International and Other Provisions) Act 2010
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- UK Public General Acts
- 2010 c. 8
- PART 6A
- CHAPTER 12
- Section 259LA
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[F1259LADeduction from taxable total profits where an amount of ordinary income arises lateU.K.
This section has no associated Explanatory Notes
(1)This section applies where—
(a)a relevant deduction in respect of a payment or quasi-payment is reduced by section 259CD, 259DF, 259GC or 259HC or by more than one of those sections,
(b)no other provision of this Part, or any equivalent provision of the law of a territory outside the United Kingdom, applies or will apply to the tax treatment of any person in respect of the payment or quasi-payment,
(c)the section or sections had effect because it was reasonable to suppose that the relevant deduction exceeded, or would exceed, the sum of the amounts of ordinary income arising, by reason of the payment or quasi-payment, to each payee for a permitted taxable period, and
(d)an amount of ordinary income (“the late income”) arises—
(i)by reason of the payment or quasi-payment, but
(ii)not as a consequence of any provision of this Part or any equivalent provision of the law of a territory outside the United Kingdom,
to a payee for a taxable period (“the late period”) that is not a permitted taxable period.
(2)An amount equal to the late income may be deducted at step 2 in section 4(2) of CTA 2010 in calculating the payer's taxable total profits of the accounting period in which the late period ends.
(3)So much of that amount (if any) as cannot be deducted, in accordance with subsection (2), at step 2 in section 4(2) of CTA 2010 in calculating the taxable total profits of the accounting period in which the late period ends—
(a)is carried forward to subsequent accounting periods of the payer, and
(b)may be so deducted for any such period, so far as it cannot be deducted under this paragraph for an earlier period.
(4)But the total amount deducted from taxable total profits under this section, in relation to a payment or quasi-payment, may not exceed the total amount by which the relevant deduction is reduced as mentioned in (1)(a).
(5)In this section “permitted taxable period”—
(a)where the relevant deduction was reduced under section 259CD, has the meaning given by section 259CC(2),
(b)where the relevant deduction was reduced under section 259DF, has the meaning given by section 259DD(2),
(c)where the relevant deduction was reduced under section 259GC, has the meaning given by section 259GB(6),
(d)where the relevant deduction was reduced under section 259HC, has the meaning given by section 259HB(4), or
(e)where the relevant deduction was reduced under two or more of the sections mentioned in the preceding paragraphs of this subsection, includes any taxable period that is a permitted period under a provision mentioned in the paragraphs concerned.]
Textual Amendments
F1Pt. 6A inserted (with effect in accordance with Sch. 10 paras. 18-21 of the amending Act) by Finance Act 2016 (c. 24), Sch. 10 para. 1
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