Related Commentary  

17(1)  Subsection (2) applies if–

(a)under the law of the territory, an amount of tax (“the spared tax”) would, but for a relief, have been payable by a company resident in the territory (“company A”) in respect of any of its profits,

(b)company A pays a dividend out of those profits to another company resident in the territory (“company B”),

(c)company B, out of profits which consist of or include the whole or part of that dividend, pays a dividend to a company resident in the United Kingdom (“company C”), and

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