411. Distributions in respect of portfolio holdings.

A dividend or other distribution1 also falls into an exempt class2 if the recipient3 holds less than 10 per cent of the issued share capital4 of the payer, is entitled to less than 10 per cent of the profits available for distribution to holders of the issued share capital of the payer, and would be entitled on a winding up to less than 10 per cent of the assets of the company available for such distribution5.

A dividend or other distribution that would otherwise fall into an exempt class by virtue of the above provision