405. Counteracting deduction/non-inclusion and double deduction mismatches.

A special statutory regime has effect for the purposes of counteracting certain cases that it is reasonable to suppose would otherwise give rise to a deduction/non-inclusion mismatch or a double deduction mismatch, by making certain adjustments to a person's treatment for corporation tax purposes1. A deduction/non-inclusion mismatch arises where an amount is deductible from a person's income without a corresponding amount of ordinary income arising to another person or where an amount of ordinary income does arise to a person but is under taxed2