Paragraph 46 Dividends from protected cell companies

After section 273B (as inserted by paragraph 45) insert—

“Dividends from protected cell companies

273C

(1)

This section applies to a dividend or other distribution made by a protected cell company that is received or accrued by—

(a)

a qualifying entity that is not a member of a group, or

(b)

a member of a group that has no members located outside of the United Kingdom.

(2)

A dividend or other distribution to which this section applies is to be treated as an excluded dividend (see section 141) for domestic purposes and domestic entity purposes.”