16U.K.After section 284 insert—
“284ASection 284: supplementary
(1)This section contains provision for determining the total of the reductions required to be made by company A because of section 284(2) in a case in which company A, or any other company to which this Chapter applies, is a dual resident investing company.
(2)If company A is not a dual resident investing company, the total of the reductions required to be made by company A is—
or, if lower, NFD.
(3)If company A is a dual resident investing company, the total of the reductions required to be made by company A is—
or, if that amount is negative or zero, nil.
(4)In subsections (2) and (3)—
NFD, TEA and TDA have the same meaning as in section 284(3), and
X is the total of the net financing deductions of all the companies to which this Chapter applies that are dual resident investing companies.”