7U.K.Section 409(1) (postponement until redemption of debits for close companies' deeply discounted securities)—
(a)in paragraph (b), after “there is a person” insert “ ( ”, and
(b)insert at the end (not as part of paragraph (d))— “ and, where it applies, the non-qualifying territory condition is met. ”
8(1)Section 410 (interpretation of section 409) is amended as follows.U.K.
(2)In subsections (3)(b) and (4)(b), after “resident” insert “ for tax purposes ”.
(3)After subsection (4) insert—
“(4A)The non-qualifying territory condition applies if C is a company; and the non-qualifying territory condition is that C is—
(a)resident for tax purposes in a non-qualifying territory at any time in the relevant period, or
(b)effectively managed in a non-taxing non-qualifying territory at any such time.”
(4)In subsection (5), for the definition of “resident” substitute—
““resident for tax purposes” means liable, under the law of the non-qualifying territory, to tax there by reason of domicile, residence or place of management, and”.
(5)After that subsection insert—
“(5A)For the purposes of this section, a non-qualifying territory is “non-taxing” if companies are not under its law liable to tax by reason of domicile, residence or place of management.”