Section 439 | Interpretation

(1)In this Chapter—

“company” means any entity listed as a company in Part A of Annex I to the Mergers Directive, and

“co-operative society” means a society registered under the Co-operative and Community Benefit Societies Act 2014 or a similar society governed by the law of a member State ....

(2)For the purposes of this Chapter, a company is resident in a relevant state if—

(a)it is within a charge to tax under the law of the relevant state as being resident for that purpose, and

(b)it is not regarded, for the purpose of any double taxation relief arrangements to which the relevant state is a party, as resident in a territory not within a relevant state.