INTM489675 - Diverted Profits Tax: application of Diverted Profits Tax: legislation 바카라 사이트“ Finance Act 2015 바카라 사이트“ core provisions: section 86 바카라 사이트“ the mismatch condition

The mismatch condition is intended to apply to cases that involve entities or transactions lacking economic substance and is similar to the rule in section 80 applicable to UK companies. The condition is met if:

  • in connection with the supplies of the goods, services, etc., arrangements are in place as a result of which provision (바카라 사이트œthe material provision바카라 사이트) is made or imposed as between the foreign company and another person (바카라 사이트œA바카라 사이트) by means of a transaction or series of transactions,
  • the participation condition is met in relation to the foreign company and A (INTM489725),
  • the material provision results in an effective tax mismatch outcome as between the foreign company and A (INTM489740),
  • the insufficient economic substance condition is met (INTM489765),
  • the effective tax mismatch outcome is not an excepted loan relationship outcome see INTM489595,
  • the foreign company and A are not both SMEs. The same definitions are used as in section 80 바카라 사이트“ see INTM489595.