[608MB Exemption for certain bodies corporate that are transparent in full treaty territory]

[608MB  Exemption for certain bodies corporate that are transparent in full treaty territory]

[(1)     This section applies where—

(a)     a body corporate formed under the laws of a full treaty territory (“the relevant territory”) is not regarded under those laws, for tax purposes, as an entity separate and distinct from its members,

(b)     the body is not resident, at any time in a tax year, in a territory that

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