Finance Act 2019

Amendment of section 130 of Principal Act (matters to be treated as distributions)

23. (1) Section 130 of the Principal Act is amended—

(a) by substituting for subsection (2B) the following:

“(2B) Subsection (2)(d)(iv) shall not apply as respects interest, other than interest to which section 452 or 845A applies, paid to a company which is a resident of—

(a) a Member State, other than the State, or

(b) the United Kingdom,

and, for the purposes of this subsection—

(i) a company is a resident of a Member State if the company is by virtue of the law of that Member State resident for the purposes of tax (being any tax imposed in the Member State which corresponds to corporation tax in the State) in such Member State, and

(ii) a company is a resident of the United Kingdom if the company is by virtue of the law of the United Kingdom resident for the purposes of tax (being any tax imposed in the United Kingdom which corresponds to corporation tax in the State) in the United Kingdom.”,

and

(b) in subsection (3)(d), in the definition of “relevant Member State”—

(i) in subparagraph (i), by deleting “or”,

(ii) in subparagraph (ii), by substituting “made, or” for “made.”, and

(iii) by inserting the following after subparagraph (ii):

“(iii) the United Kingdom.”.

(2) This section shall apply from the day (at the time thereon appointed in that behalf under the Act next mentioned) that Part 6 of the Withdrawal of the United Kingdom from the European Union (Consequential Provisions) Act 2019 comes into operation.