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(iii) any foreign tax borne by a company that would be allowed under paragraph 9B of Schedule 24 if in subparagraphs (2) and (3) “and is connected with the relevant company” in each place where it occurs were deleted.

(b) any foreign tax that would be treated as tax paid by the subsidiary company under paragraph 9B of Schedule 24 if—

(3) Where by virtue of subsection (2)(a)or (2A) a company is to be allowed credit for tax payable under the laws of a Member State other than the State, Schedule 24 shall apply for the purposes of that subsection as if—

(b) references in Schedule 24 to a dividend were references to a distribution within the meaning of this section.

(b) notwithstanding Chapter 2 of Part 4, the distribution shall not be a dividend to which that Chapter applies.

(b) notwithstanding Chapter 2 of Part 4, the distribution shall not be a dividend to which that Chapter applies.

(6) Subsection (5) shall not have effect in relation to a distribution made to a parent company if the majority of the voting rights in the parent company are controlled directly or indirectly by persons, other than persons who by virtue of the law of any relevant territory are resident for the purposes of tax in such a relevant territory (within the meaning assigned by section 172A), unless it is shown that the parent company exists for bona fide commercial reasons and does not form part of any arrangement or scheme of which the main purpose, or one of the main purposes, is the avoidance of liability to income tax (including dividend withholding tax under Chapter 8A of Part 6), corporation tax or capital gains tax.

(5) Chapter 8A of Part 6, other than section 172K, shall not apply to a distribution made to a parent company which is not resident in the State by its subsidiary which is a company resident in the State.

“bilateral agreement” means any arrangements arrangements having the force of law by virtue of section 826(1), protocol or other agreement between the Government and the government of another Member State;

(a) the provisions of that subsection were arrangements arrangements having the force of law by virtue of section 826(1) providing that tax so payable shall be allowed as a credit against tax payable in the State, and