2. A company (“the first company”) receiving interest, rents or royalties in an accounting period directly or indirectly from a Dutch company (“the second company”) which is connected with the first company within the meaning of section 839 of the Taxes Act, in circumstances where– (a)the second company does not satisfy the income and gains requirement in regulation 5 as respects its accounting period in which the interest, rents or royalties were paid, and (b)the aggregate of the non-local source income of the first company in its accounting period in question and the interest, rents and royalties received by it from the second company in that period exceeds whichever is the greater of– (i)£50,000 or, where that period is less than twelve months in duration, that amount proportionately reduced, and (ii)an amount equal to ten per cent. of its commercially quantified income arising in that period. |