Section 259HC Counteraction of the multinational payee deduction/non-inclusion mismatchF1F2

if paragraph (b) of Condition C in subsection (5) of section 259HA is met, an amount equal to the multinational payee deduction/non-inclusion mismatch mentioned in subsection (6) of that section is to be treated as income arising to the multinational company in the United Kingdom (and nowhere else) for the payment period, and

in any other case, the relevant deduction that may be deducted from the payer’s income for that period is to be reduced by that amount.