A dividend or other distribution1 of a company2 that is received in an accounting period3 of the recipient4 in which the recipient is a small company5 is exempt if:
(1) the payer6 is a resident7 of (and only of) the United Kingdom8 or a qualifying territory9 at the time the distribution is received;
(2) the distribution is not of a specified kind10 in respect of non-commercial or special securities;
(3) no deduction is allowed to a resident of any territory outside the United Kingdom under the law of that territory in respect of the distribution; and
(4) the distribution
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