Legislation – Finance Act 2024
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Schedule 12Pillar Two
Part 3Domestic top-up tax
Dividends from protected cell companies
46
“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.”