(1) In this section -
'EEA Agreement' means the Agreement on the European Economic Area signed at Oporto on 2 May 1992, as adjusted by all subsequent amendments to that Agreement;
'EEA state' means a state which is a contracting party to the EEA Agreement;
'qualifying non-resident person', in relation to a distribution, means the person beneficially entitled to the distribution, being -
(a) a person, other than a company, who -
(i) is neither resident nor ordinarily resident in the State, and
(ii) is, by virtue of the law of a relevant territory, resident for the purposes of tax in the relevant territory,
(b) a company which is not resident in the State and -
(i) is, by virtue of the law of a relevant territory, resident for the purposes of tax in the relevant territory, but is not under the control, whether directly or indirectly, of a person or persons who is or are resident in the State,
(ii) is under the control, whether directly or indirectly, of a person or persons who, by virtue
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