96 Payments by and to companies

96  Payments by and to companies

(1)     Where a capital payment is received from a qualifying company which is controlled by the trustees of a settlement at the time it is received, for the purposes of sections 87 to 90 [and Schedule 4C] it shall be treated as received from the trustees.

(2)     Where a capital payment is received from the trustees of a settlement (or treated as so received by virtue of subsection (1) above) and it is received by a non-resident qualifying company, the rules in subsections (3) to (6) below shall apply for the purposes of sections 87 to 90 [and Schedule 4C].

(3)     If the company is controlled by one person alone at the time the payment is received, and that person is then resident . . . in the United Kingdom, it shall be treated as a capital payment received by that person.

(4)     If the company is controlled by 2 or more persons (taking each one separately) at the time the payment is received, then—

(a)     if one of them is then resident . . . in the United Kingdom, it shall be treated as a capital payment received by that

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