(1) Chapter 6 of Part 8 of the Principal Act is amended by inserting the following section after section 267K:

"267L. Application of this Chapter to certain payments made to companies in Switzerland.

(1) This section applies to a payment, being interest or royalties, made to or for the benefit of -

(a) where paragraph (b) does not apply, a company which -

(i) is the beneficial owner of the interest, or as the case may be the royalties,

(ii) is, by virtue of the law of Switzerland, resident for the purposes of tax in Switzerland, and

(iii) is not treated, by virtue of any arrangements made by the government of Switzerland with the government of any territory for the purposes of tax, as resident in any territory which is not -

(I) a Member State of the European Communities, or

(II) Switzerland,

or

(b) a permanent establishment situated in Switzerland through which a company carries on business in Switzerland, being a permanent establishment which would, in accordance with the Directive, be treated as the beneficial owner of the interest, or as the case may be the royalties.