26U.K.In section 259BC (the basic rules), after subsection (8) insert—
“(8A)Income is to be treated as “ordinary income” if it would fall to be brought into account for the purpose of calculating taxable profits of a person but for the fact that the person is a qualifying institutional investor (and, if the person is based in a territory under the law of which there is no relevant tax on income of the kind in question, if the territory had such a tax).
For the meaning of “qualifying institutional investor” see section 259NDA.”