Exemption where company resident in specified territory608JA

1

Section 608A does not apply in relation to a company for a tax year if—

a

the company is resident in a specified territory throughout the tax year,

b

UK-derived amounts arising to the company in the tax year are chargeable to tax under the laws of the territory,

c

where those amounts are chargeable only if remitted or otherwise received in the territory, the amounts are remitted or otherwise received there in the tax year,

d

the amount of tax which is paid in the territory in respect of the UK-derived amounts is not determined under designer tax provisions, and

e

the company is not, at any time in the tax year, involved in an arrangement the main purpose, or one of the main purposes, of which is to obtain a tax advantage for itself or any other person.

2

For the purposes of this section—

a

section 608D (meaning of residence) applies as if subsections (2)(b), (4) and (5) were omitted;

b

“specified territory” means a territory specified in regulations made by the Commissioners.

3

Regulations under this section may have effect from a date before the day on which they are made, except insofar as they result in a territory ceasing to be specified.