Paragraph 49

that the overseas company operates qualifying ships;

that more than 50% of the voting power in the overseas company is held by a company resident in a F1the United Kingdom F2..., or that two or more companies each of which is resident in a the United Kingdom ... hold in aggregate more than 50% of that voting power;

that F3, where the overseas company operates qualifying ships, the 75% limit is not exceeded in relation to the overseas company in any accounting period in respect of which the distribution is paid;

that all the income of the overseas company is such that, if it were a tonnage tax company, it would be relevant shipping income;

that the distribution is paid entirely out of profits arising at a time when—

the profits of the overseas company out of which the distribution is paid are subject to a tax on profits (in the country of residence of the company or elsewhere, or partly in that country and partly elsewhere).