Taxation (International and Other Provisions) Act 2010 section 259B

"Tax" means certain taxes on income and includes foreign tax etc.

Section 259B defines what counts as "tax" for the purposes of the hybrid mismatch rules in Part 6A of the Act, covering both UK and overseas taxes on income.

• For the hybrid mismatch rules, "tax" means UK income tax, corporation tax on income, diverted profits tax, the CFC charge, and their foreign equivalents
• Foreign tax only qualifies if it is a national-level tax on income that corresponds to UK income tax or corporation tax on income — taxes levied by provinces, states, municipalities or other local bodies are excluded
• A foreign tax does not qualify where income arises to one entity but is brought into account for tax by a different entity under a look-through or flow-through regime in the overseas territory
• Withholding taxes are entirely disregarded for the purposes of the hybrid mismatch rules, and where a territory has no concept of tax residence, general residence in that territory is used instead