[259JB Counteraction where mismatch arises because of a dual resident company]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[Counteraction]

[259JB  Counteraction where mismatch arises because of a dual resident company]

[(1)     This section applies where the dual territory double deduction amount arises by reason of the company being a dual resident company.

(2)     For corporation tax purposes, the dual territory double deduction amount may not be deducted from the company's income for the deduction period unless it is deducted from dual inclusion income of the company for that period.

(3)     So much of the dual territory double deduction amount (if any) as, by virtue of subsection (2), cannot be deducted from the company's income for the deduction period—

(a)     is carried forward to subsequent accounting periods of the company, and

(b)     for corporation tax purposes, may be deducted from dual inclusion income of the company for any such period (and not from any other income), so far as it cannot

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