3ZA

A tax is not within paragraph (a) or (b) of subsection (2) so far as it is charged on income that—

a

has arisen to an entity that—

i

is not subject to the tax (as regards that income), and

ii

is, under the law of the territory referred to in that subsection, regarded as being a person for the purposes of the tax, but

b

is to be brought into account for the purposes of that tax by a different entity.