Taxation (International and Other Provisions) Act 2010 Schedule 10 Part 4A

Index of defined expressions used in Part 6A

Schedule 10 Part 4A provides a comprehensive index of all the defined expressions used throughout Part 6A of the Act, which deals with hybrid and other mismatches, directing readers to the specific sections where each term is defined.

• The index covers over 60 defined terms used across the various chapters of Part 6A, ranging from fundamental concepts such as "payment", "payer", "payee" and "tax" to highly specific terms such as "hybrid transfer arrangement" and "dual territory double deduction amount".
• Many terms have different definitions depending on which chapter of Part 6A they appear in — for example, "excessive PE deduction" is defined separately for Chapter 6 and Chapter 11, and "parent jurisdiction" has distinct definitions in Chapters 6, 8 and 10.
• Core structural concepts — including "control group", "related" persons, "hybrid entity", "investor", "financial instrument" and "permanent establishment" — are defined in the key definitions chapter (Chapter 2) or the interpretation chapter (Chapter 14) and apply across the whole of Part 6A.
• Chapter-specific terms relate to the particular type of mismatch each chapter addresses, such as hybrid payer mismatches (Chapter 5), hybrid payee mismatches (Chapter 7), hybrid entity double deduction mismatches (Chapter 9), dual territory double deduction cases (Chapter 10) and imported mismatches (Chapter 11).

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