Section 931D | Exemption from charge to tax
From legislation.gov.uk
A dividend or other distribution of a company that is received in an accounting period of the recipient in which the recipient is not a small company is exempt if—
(a)the distribution falls into an exempt class (see sections 931E to 931Q),
(b)the distribution is not of a kind mentioned in paragraph E or F in section 1000(1) of CTA 2010 (certain non-dividend distributions), and
(c)no deduction is allowed to a resident of any territory outside the United Kingdom under the law of that territory in respect of the distribution.