{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-259NF",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-259NF.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "section/259NF",
  "kind": "section",
  "number": "259NF",
  "heading": "Definitions",
  "text": "In this Part—\n“arrangement” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable);\n“CFC” and “CFC charge” have the meaning given by section 259B(4);\n“the Commissioners” means the Commissioners for Her Majesty's Revenue and Customs;\n“control group” has the meaning given by section 259NB;\n“financial instrument” has the meaning given by section 259N;\n“foreign CFC” and “foreign CFC charge” have the meaning given by section 259B(4);\n“hybrid entity” has the meaning given by section 259BE;\n“investor”, in relation to a hybrid entity, has the meaning given by section 259BE(4);\n“investor jurisdiction” has the meaning given by section 259BE(4);\n“ordinary income” is to be read in accordance with sections 259BC and 259BD;\n“payee”—\n(a)in relation to a payment, has the meaning given by section 259BB(6)(a), and\n(b)in relation to a quasi-payment, has the meaning given by section 259BB(6)(b);\n“payee jurisdiction” has the meaning given by 259BB(9);\n“payer”—\n(a)in relation to a payment, has the meaning given by section 259BB(1)(a), and\n(b)in relation to a quasi-payment, has the meaning given by section 259BB(2);\n“payment” has the meaning given by section 259BB(1);\n“payment period”—\n(a)in relation to a payment, has the meaning given by section 259BB(1)(b), and\n(b)in relation to a quasi-payment, has the meaning given by section 259BB(2);\n“permanent establishment” has the meaning given by section 259BF;\n“quasi-payment” has the meaning given by section 259BB(2) to (5);\n“related” has the meaning given by section 259NC;\n“relevant deduction”—\n(a)in relation to a payment, has the meaning given by section 259BB(1)(b), and\n(b)in relation to a quasi-payment, has the meaning given by section 259BB(2)(a);\n“relevant investment fund” has the meaning given by section 259NA;\n“tax” has the meaning given by section 259B;\n“taxable period” means—\n(a)in relation to corporation tax, an accounting period,\n(b)in relation to income tax, a tax year,\n(c)in relation to the CFC charge, a relevant corporation tax accounting period (within the meaning given by section 371BC(3)),\n(d)in relation to a foreign CFC charge, a period (by whatever name known) that corresponds to a relevant corporation tax accounting period, and\n(e)in relation to any other tax, a period for which the tax is charged;\n“taxable profits” is to be read in accordance with sections 259BC(2) and 259BD(5).",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 6A inserted (with effect in accordance with Sch. 10 paras. 18-21 of the amending Act) by Finance Act 2016 (c. 24), Sch. 10 para. 1"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/259NF",
    "retrieved_at": "2026-10-29T09:10:17.008829+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}