(1) Chapter 2 of Part 35 of the Principal Act is amended by inserting the following section after section 831:

"831A. Treatment of distributions to certain parent companies.

(1)

(a) In this section -

'company', in relation to a company that is resident for the purposes of tax in Switzerland, means a company which -

(i) takes one of the forms specified in Article 15 of the Agreement attached to the Council Decision (2004/911/EC) of 2 June 2004 on the signing and conclusion of the Agreement between the European Community and the Swiss Confederation providing for measures equivalent to those laid down in Council Directive 2003/48/EC of 3 June 2003 on taxation of savings income in the form of interest payments and the accompanying Memorandum of Understanding [1OJ No. L381, 28.12.2004, p.32], and

(ii) is subject to tax in Switzerland without being exempt;

'parent company' means a company which controls not less than 25 per cent of the voting power in another company;

'tax', in relation to Switzerland, means any tax imposed in Switzerland which corresponds to income tax or corporation tax in the State.

(b) For the purposes of this section a company shall be a subsidiary of another company which holds voting rights in it where the other company's holding of those rights is sufficient for that other company to be a parent company.