Regulation 2 Excluded companies

A territory which satisfies section 931C(1)(a) and (b) is nevertheless not a qualifying territory for the purpose of section 931B^f1 in respect of the payer of the distribution if the payer is an excluded company.

For the purposes of this regulation, an excluded company is one which is excluded from one or more of the benefits of any double taxation relief arrangements for the time being in force in relation to that territory.