A dividend or other distribution1 which would otherwise fall within an exempt class2 does not so fall if it is made as part of a tax advantage scheme3 and any of the following conditions are met4. The conditions are that:
(1) a deduction is allowed to a resident of any territory outside the United Kingdom5 under the law of that territory in respect of an amount determined by reference to the distribution6;
(2) the scheme includes a payment, or the giving up of a right to income, by a relevant person7 where the payment is made or the right
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