831. Implementation of Council Directive No. 90/435/EEC concerning the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States.

(1)

(a) In this section -

"bilateral agreement" means any arrangements having the force of law by virtue of section 826(1), protocol or other agreement between the Government and the government of another Member State;

"company" means a company of a Member State;

"company of a Member State" has the meaning assigned to it by Article 2 of the Directive;

"the Directive" means Council Directive 2011/96/EU of 30 November 2011 [OJ No. L345, 29.12.2011, p.8], as amended, on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States;

"distribution" means income from shares or from other rights, not being debt claims, to participate in a company's profits, and includes any amount assimilated to income from shares under the taxation laws of the State of which the company making the distribution is resident;

"foreign tax" means any tax which -

(i) is payable under the laws of a Member State other than the State, and

(ii)

(I) is specified i

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