6(1)Section 407 (postponement until redemption of debits for connected companies' deeply discounted securities) is amended as follows.U.K.
(2)In subsection (1)—
(a)in paragraph (b), after “company” insert “ (“the creditor company” ,
(b)omit the “and” at the end of paragraph (d), and
(c)insert at the end “, and
(f)the condition in subsection (1A) is met.”
(3)After that subsection insert—
“(1A)The condition is that the creditor company 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)Insert at the end—
“(6)For the purposes of this section—
(a)“non-qualifying territory” has the meaning given by paragraph 5E of Schedule 28AA to ICTA,
(b)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, and
(c)“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.”