Dealing with transparency and entities subject to qualifying dividend regime Dealing with transparency and entities subject to qualifying dividend regime

United Kingdom

1. 167Underlying profits of hybrids
2. 168Underlying profits of transparent ... entities
3. 169Certain non tax resident entities to be treated as flow-through entities
4. 170Adjustments for ultimate parent that is a flow-through entity
5. 171Ultimate parent subject to qualifying dividend regime
6. 172Application of section 171 to members in the same territory as the ultimate parent