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Taxation (International and Other Provisions) Act 2010

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Taxation (International and Other Provisions) Act 2010, Section 259BE is up to date with all changes known to be in force on or before 22 November 2019. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations. Help about Changes to Legislation

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[F1259BEMeaning of “hybrid entity”, “investor” and “investor jurisdiction”U.K.
This section has no associated Explanatory Notes

(1)For the purposes of this Part, an entity is “hybrid” if it meets conditions A and B.

(2)Condition A is that the entity is regarded as being a person for tax purposes under the law of any territory.

(3)Condition B is that—

(a)some or all of the entity's income or profits are treated (or would be if there were any) for the purposes of a tax charged under the law of any territory, as the income or profits of a person or persons other than the person mentioned in subsection (2), or

(b)under the law of a territory other than the one mentioned in subsection (2), the entity is not regarded as a distinct and separate person to an entity or entities that are distinct and separate persons under the law of the territory mentioned in that subsection.

(4)For the purposes of this Part—

(a)where subsection (3)(a) applies, a person who is treated as having the income or profits of the hybrid entity is an “investor” in it,

(b)where subsection (3)(b) applies, an entity that—

(i)is regarded as a distinct and separate person to the hybrid entity under the law of the territory mentioned in subsection (2), but

(ii)is not regarded as a distinct and separate person to the hybrid entity under the law of another territory,

is an “investor” in the hybrid entity, and

(c)any territory under the law of which an investor is within the charge to a tax is an “investor jurisdiction” in relation to that investor.]

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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