(1) This section applies to a relevant distribution where -
(a) a company resident in the State makes a relevant distribution to -
(i) an associated entity that is resident in a specified territory and is not resident in another territory that is not a specified territory, or
(ii) a permanent establishment of an associated entity which is situated in a specified territory,
(b) to the extent that the relevant distribution is not an excluded payment, and
(c) to the extent that the relevant distribution is made out of income, profits or gains which have not been chargeable, directly or indirectly, to -
(ii) foreign tax at a nominal rate greater than zero per cent,
(iii) a controlled foreign company charge,
(iv) a supplemental tax, or
(v) any other tax which is similar to any of the taxes referred to in subparagraphs (i) to (iv).
(2) Sections 140(3)(a), 142(2), 153(4), 172B(7), 172D(2) and 172E(1) shall not apply to a relevant distribution to which this section applies.
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