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Version date: 1 January 2024 - onwards
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153. Distributions to certain non-residents.

(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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