Schedules

Schedule 12 Pillar Two

Part 3 Domestic top-up tax

Dividends from protected cell companies

46 After section 273B (as inserted by paragraph 45) insert—

“273C Dividends 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.”