Part 5Loan Relationships

Chapter 13European cross-border transfers of business

Interpretation

430Interpretation

(1)

In this Chapter “company” means any entity listed as a company in F1Part A of Annex I to the Mergers Directive.

(2)

For the purposes of this Chapter, a company is resident in a F2relevant state if—

(a)

it is within a charge to tax under the law of the F3relevant state as being resident for that purpose, and

(b)

it is not regarded, for the purpose of any double taxation relief arrangements to which the F3relevant state is a party, as resident in a territory not within a F2relevant state.