1U.K.After section 259B(3) of TIOPA 2010 insert—
“(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.”