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Taxation (International and Other Provisions) Act 2010

Taxation (International and Other Provisions) Act 2010

2010 CHAPTER 8

Commentary on Sections

Part 4: Transfer pricing

Chapter 5: Position of guarantor of affected person’s liabilities under a security issued by the person
Section 191: When sections 192 to 194 apply

390.This section explains that section 192 (as supplemented by sections 193 and 194) applies when interest paid under a security is disallowed under section 147 as a result of the operation of section 153 in the case of a guarantee given for liabilities under the security. It is based on paragraphs 1A(7), (9) and (10) and 6D(1) and (10) of Schedule 28AA to ICTA.

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