(1) Part 19 of the Principal Act is hereby amended in Chapter 4 by the substitution for section 590 of the following section:
"590. Attribution to participators of chargeable gains accruing to non-resident company.
(1) In this section -
(a) 'participator', in relation to a company, has the meaning assigned to it by section 433(1);
(b) references to a person's interest as a participator in a company are references to the interest in the company which is represented by all the factors by reference to which the person falls to be treated as such a participator; and
(c) references to the extent of such an interest are references to the proportion of the interests as participators of all the participators in the company (including any who are not resident or ordinarily resident in the State) which on a just and reasonable apportionment is represented by that interest.
(2) For the purposes of this section, where -
(a) the interest of any person in a company is wholly or partly represented by
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