For the purposes of the involvement of entities or transactions lacking economic substance (¶777-280), the material provision results in an effective tax mismatch outcome as between the company C and person P if:

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

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