Section 931N | Schemes involving distributions for which deductions are given
From legislation.gov.uk
(1)This section applies to a dividend or other distribution that would, apart from this section, fall into an exempt class.
(2)The distribution does not fall into an exempt class if—
(a)the distribution is made as part of a tax advantage scheme, and
(b)the following condition is met.
(3)The condition is that a deduction is allowed to a resident of any territory outside the United Kingdom under the law of that territory in respect of an amount determined by reference to the distribution.