Commentary

D4.742 Deductions cases—tax implications

Corporate tax
Corporate tax | Commentary

D4.742 Deductions cases—tax implications

Corporate tax | Commentary

D4.742 Deductions cases—tax implications

The provisions in this article were repealed from 1 January 2017. From 1 January 2017, the rules dealing with hybrid and other mismatches apply; see see D4.701 onwards. The latter rules were introduced as part of the OECD BEPS action plan on international corporate tax avoidance.

If a company receives a notice and conditions (a)–(d) (see D4.741) are in fact satisfied at the time it is given, the company must compute (or recompute) its income or chargeable gains for corporation tax purposes or its liability to corporation tax for the specified accounting period and any subsequent accounting period in accordance with the following rules—1

  1.  

    (a)     the rule against double deduction2 — no deduction is allowable for corporation tax purposes in respect of the transaction specified in the notice to the extent that, in relation to the expense in question, an amount may be otherwise deducted or allowed in computing the income, profits or losses of any person for the purposes of any tax (including foreign tax within the meaning of CTA 2010, s 187 (formerly ICTA 1988, s 403D); see D2.260) or would

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