253 Disqualified and qualified refundable imputation taxes

253  Disqualified and qualified refundable imputation taxes

(1)     An amount of tax payable by a member of a multinational group is “disqualified refundable imputation tax” if—

(a)     it is—

(i)     [as a result of a dividend made by the member,] refundable to the beneficial owner of the dividend,

(ii)     creditable by the beneficial owner of such a dividend against a tax liability other than a tax liability in respect of that dividend, or

(iii)     refundable to an entity upon the distribution of a dividend, and

(b)     it is not qualified refundable imputation tax.

(2)

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