[79B Attribution to trustees of gains of non-resident companies]

[79B  Attribution to trustees of gains of non-resident companies]

[(1)     This section applies where [the] trustees of a settlement are participators—

(a)     in a close company, or

(b)     in a company that is not resident in the United Kingdom but would be a close company if it were resident in the United Kingdom.

For this purpose “participator” has the same meaning as in [section 3 (see section 3B)].

(2)     Where this section applies, nothing in any double taxation relief arrangements

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