For the purposes of the mismatch condition in connection with a non-UK company avoiding a UK taxable presence (¶777-020), the material provision results in an effective tax mismatch outcome as between the foreign company and person A if:

(1)in that accounting period, in relation to a relevant tax (below), it results in one or both of expenses of the foreign company for which a deduction has been taken into account in computing the amount of the relevant tax payable by the foreign company; or a reduction in the income of the foreign company which would have otherwise been taken into account in computing the amount of a relevant tax payable by the foreign company;

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