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2A scheme falls within this Part if a party to a transaction forming part of the scheme is a hybrid entity.
3(1)An entity is a hybrid entity if—
(a)under the tax law of any territory, the entity is regarded as being a person, and
(b)the entity’s profits or gains are, for the purposes of a relevant tax imposed under the law of any territory, treated as the profits or gains of a person or persons other than that person.
(2)The requirement in sub-paragraph (1)(b) is not to be regarded as satisfied in relation to an entity by reason only of its profits or gains being subject to a rule similar to that in section 747(3) of ICTA (imputation of chargeable profits of controlled foreign company) and having effect under the tax law of any territory outside the United Kingdom.
(3)For the purposes of this paragraph, the following are relevant taxes—
(a)income tax;
(b)corporation tax;
(c)any tax of a similar character to income tax or corporation tax that is imposed by the law of a territory other than the United Kingdom.
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