(1)This section applies if—
(a)companies give a notice under section 963(2) in pursuance of an agreement, and
(b)the company to which the surrender is made makes a payment under the agreement to the company by which the surrender is made that does not exceed the amount specified in the notice.
(2)The payment—
(a)is not to be taken into account in determining profits or losses of either company for corporation tax purposes, and
(b)is not to be regarded for the purposes of the Corporation Tax Acts as a distribution.