(1) In this section a "holder of excessive rights" means a person, or connected persons within the meaning of section 10, or connected persons within the meaning of section 10, who is beneficially entitled, directly or indirectly, to at least 10 per cent of the units in an IREF.
(2) Notwithstanding any other provision of the Tax Acts -
(a) for the purposes of affording relief under an arrangement made with the government of a territory outside the State having the force of law under the procedures set out in section 826(1), the IREF taxable amount in respect of an IREF taxable event and a unit holder -
(i) who is a holder of excessive rights, is income from immovable property, and
(ii) who is not a holder of excessive rights, shall be treated as a dividend,
(b) in respect of a unit holder who is a specified person, the IREF taxable amount shall be chargeable to income tax under Case V of Schedule D and shall be treated as income -
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