http://www.legislation.gov.uk/ukpga/2010/8/section/259JCTaxation (International and Other Provisions) Act 2010An Act to restate, with minor changes, certain enactments relating to tax; to make provision for purposes connected with the restatement of enactments by other tax law rewrite Acts; and for connected purposes.texttext/xmlenStatute Law Database2026-05-05Expert Participation2026-03-18 PART 6ACHAPTER 10259JC1This section applies where—athe dual territory double deduction amount arises by reason of the company being a relevant multinational company, andbthe United Kingdom is the parent jurisdiction.2If some or all of the dual territory double deduction amount is (in substance) deducted (“the impermissible overseas deduction”), for the purposes of a tax under the law of a territory outside the United Kingdom, from the income of any person, for any taxable period, that is not dual inclusion income of the company—athe dual territory double deduction amount that may be deducted, for corporation tax purposes, from the company's income for the deduction period is reduced by the amount of the impermissible overseas deduction, andbsuch just and reasonable adjustments (if any) as are required to give effect to that reduction, for corporation tax purposes, are to be made.3Any adjustment required to be made under subsection (2) may be made (whether or not by an officer of Revenue and Customs)—aby way of an assessment, the modification of an assessment, amendment or disallowance of a claim, or otherwise, andbdespite any time limit imposed by or under any enactment.4In this section “dual inclusion income” of the company means an amount that is both—aordinary income of the company for an accounting period for corporation tax purposes, andbordinary income of the company for a permitted taxable period for the purposes of a tax charged under the law of a territory outside the United Kingdom.5A taxable period is “permitted” for the purposes of paragraph (b) of subsection (4) if—athe period begins before the end of 12 months after the end of the accounting period of the company mentioned in paragraph (a) of that subsection, orbwhere the period begins after that—ia claim has been made for the period to be a permitted period in relation to the amount of ordinary income, andiiit is just and reasonable for the amount of ordinary income to arise for that taxable period rather than an earlier period.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