S259LA TIOPA 2010 applies where a deduction arising from a payment or quasi-payment is reduced by application of Chapters 3, 4, 7 and 8 and the only reason for the reduction is that the ordinary income arose to the payee outside the permitted period. If an amount of ordinary income arises in a later period, an amount equal to the amount of that ordinary income, but no more than the reduction of the allowable deduction, may be deducted in calculating the taxable profits of the payee for that later period.

This section applies where a deduction has been denied to a payer within the charge to corporation tax (the UK payer) because the relevant payment or quasi-payment gave rise to

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