Part 5Loan Relationships

Chapter 14European cross-border mergers

Interpretation

439Interpretation

(1)In this Chapter—

(2)For the purposes of this Chapter, a company is resident in a member State if—

(a)it is within a charge to tax under the law of the State as being resident for that purpose, and

(b)it is not regarded, for the purpose of any double taxation relief arrangements to which the State is a party, as resident in a territory not within a member State.