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(1)No liability to income tax arises in respect of a payment of interest or a payment of a royalty if, at the time the payment is made, the following conditions are satisfied.
(2)Condition 1 is that the person making the payment is—
(a)a UK company (but not such a company’s permanent establishment in a territory other than the United Kingdom), or
(b)a UK permanent establishment of an EU company.
See section 99(2) as to when a permanent establishment is to be treated as the person making the payment.
(3)Condition 2 is that the person beneficially entitled to the income in respect of which the payment is made is an EU company (but not such a company’s UK permanent establishment or non-EU permanent establishment).
See section 99(3) as to when a permanent establishment is to be treated as the person beneficially entitled to the income in respect of which the payment is made.
(4)Condition 3 is that the company in Condition 1 and the company in Condition 2 are 25% associates (see section 99(4)).
(5)Condition 4 is that, if the payment is a payment of interest, the Board has issued an exemption notice in accordance with regulations under section 100.
(6)This section is subject to—
section 103 (special relationships), and
section 104 (anti-avoidance).
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