INTM551090 - Hybrids: financial instruments (Chapter 3): conditions to be satisfied: condition B

Condition B of s259CA TIOPA 2010 requires

• the payer to be within the charge to UK corporation tax for a relevant payment period, or
• a payee to be within the charge to UK corporation tax for an accounting period that falls wholly or partly within a relevant payment period

The relevant payment period is the taxable period of the payer in which an amount may be deducted, in relation to the payment or quasi-payment.