F1PART 6AHybrid and other mismatches
CHAPTER 14Interpretation
Definitions
259NFDefinitions
In this Part—
“arrangement” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable);
“CFC” and “CFC charge” have the meaning given by section 259B(4);
“the Commissioners” means the Commissioners for Her Majesty's Revenue and Customs;
“control group” has the meaning given by section 259NB;
“financial instrument” has the meaning given by section 259N;
“foreign CFC” and “foreign CFC charge” have the meaning given by section 259B(4);
“hybrid entity” has the meaning given by section 259BE;
“investor”, in relation to a hybrid entity, has the meaning given by section 259BE(4);
“investor jurisdiction” has the meaning given by section 259BE(4);
“ordinary income” is to be read in accordance with sections 259BC and 259BD;
“payee”—
- a
in relation to a payment, has the meaning given by section 259BB(6)(a), and
- b
in relation to a quasi-payment, has the meaning given by section 259BB(6)(b);
- a
“payee jurisdiction” has the meaning given by 259BB(9);
“payer”—
- a
in relation to a payment, has the meaning given by section 259BB(1)(a), and
- b
in relation to a quasi-payment, has the meaning given by section 259BB(2);
- a
“payment” has the meaning given by section 259BB(1);
“payment period”—
- a
in relation to a payment, has the meaning given by section 259BB(1)(b), and
- b
in relation to a quasi-payment, has the meaning given by section 259BB(2);
- a
“permanent establishment” has the meaning given by section 259BF;
“quasi-payment” has the meaning given by section 259BB(2) to (5);
“related” has the meaning given by section 259NC;
“relevant deduction”—
- a
in relation to a payment, has the meaning given by section 259BB(1)(b), and
- b
in relation to a quasi-payment, has the meaning given by section 259BB(2)(a);
- a
“relevant investment fund” has the meaning given by section 259NA;
“tax” has the meaning given by section 259B;
“taxable period” means—
- a
in relation to corporation tax, an accounting period,
- b
in relation to income tax, a tax year,
- c
in relation to the CFC charge, a relevant corporation tax accounting period (within the meaning given by section 371BC(3)),
- d
in relation to a foreign CFC charge, a period (by whatever name known) that corresponds to a relevant corporation tax accounting period, and
- e
in relation to any other tax, a period for which the tax is charged;
- a
“taxable profits” is to be read in accordance with sections 259BC(2) and 259BD(5).
Pt. 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