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

F3section 1285 of the Corporation Tax Act 2009 (exemption from corporation tax);

F6b

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3

The distribution shall be treated for the purposes of F1income 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 taxF4as dividends of a non-UK resident company chargeable under Chapter 2 of Part 10 of the Corporation Tax Act 2009.

F24

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5

In this paragraph “distribution” has the same meaning as it has in the Corporation Taxes Acts by virtue of F5Chapter 2 of Part 23 of the Corporation Tax Act 2010 (company distributions).