273CDividends from protected cell companies

1

This section applies to a dividend or other distribution made by a protected cell company that is received or accrued by—

a

a qualifying entity that is not a member of a group, or

b

a member of a group that has no members located outside of the United Kingdom.

2

A dividend or other distribution to which this section applies is to be treated as an excluded dividend (see section 141) for domestic purposes and domestic entity purposes.