Section 371ED Arrangements in lieu of dividends etc to UK resident companies etcF1

with a UK resident company connected with the CFC, or

with a non-UK resident company connected with the CFC for the purposes of a UK permanent establishment of the non-UK resident company, and

that the arrangement is made as an alternative to the CFC paying dividends or making any other distribution to the other company (directly or indirectly), and

that the main reason, or one of the main reasons, for that is a reason relating to a liability, or potential liability, of any person to tax or duty imposed under the law of any territory.