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(b) (i) The reference in the definition of “relevant dividends” to “a foreign subsidiary” means a 51 per cent subsidiary of a company where the company is resident in the State and the subsidiary is a resident of the United States of America or of a territory with the government of which arrangements having the force of law by virtue of section 826 section 826(1)(a) section 826(1) have been made.

a company shall be regarded as being a resident of a territory other than the United States of America if it is so regarded under arrangements made with the government of that territory and having the force of law by virtue of section 826 section 826(1)(a) section 826(1).