SCHEDULES

SCHEDULE 3 Tax

Distributions

6

1

This paragraph applies where the Corporation makes a distribution during the exempt period.

2

The following provisions shall not apply in relation to the distribution—

a

F4section 1285 of the Corporation Tax Act 2009 (exemption from corporation tax);

b

F6section 1109 of the Corporation Tax Act 2010 (tax credits for certain recipients of exempt qualifying distributions)F1or section 397 of the Income Tax (Trading and Other Income) Act 2005 (tax credits for qualifying distributions: UK residents and eligible non-UK residents) (tax credits).

3

The distribution shall be treated for the purposes of F2income tax as dividends of a non-UK resident company chargeable under Chapter 4 of Part 4 of the Income Tax (Trading and Other Income) Act 2005 (and accordingly as relevant foreign income for the purposes of that Act), and for the purposes of corporation taxF5as dividends of a non-UK resident company chargeable under Chapter 2 of Part 10 of the Corporation Tax Act 2009.

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5

In this paragraph “distribution” has the same meaning as it has in the Corporation Taxes Acts by virtue of F7Chapter 2 of Part 23 of the Corporation Tax Act 2010 (company distributions).