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(f) in relation to each of the two entities (in this paragraph referred to as ‘the first-mentioned entity’), an individual (in this paragraph referred to as ‘the first-mentioned individual’) and, subject to subsection (3A), any other entity or individual connected (within the meaning of section 10) with the first-mentioned individual—

(I) where the first-mentioned entity is a company, if the whole of the profits of that entity were distributed, entitle the first-mentioned individual, and any other entity or individual connected (within the meaning of section 10) with the first-mentioned individual, to receive more than 50 per cent of the profits so distributed, or

(II) where the first-mentioned entity is not a company, entitle the first-mentioned individual, and any other entity or individual connected (within the meaning of section 10) with the first-mentioned individual, to a share of more than 50 per cent of the profits of the first-mentioned entity,

(3A)(a) For the purposes of subsection (3)(f), subsections (5) and (8) of section 10 shall not operate so as to connect an individual (in this paragraph referred to as ‘the first-mentioned individual’) with any other entity or individual by reason only of the first-mentioned individual and such other entity or individual being in partnership where—

where the first-mentioned individual, or persons connected with the first-mentioned individual, would not otherwise be connected (within the meaning of section 10) with such other entity or individual.

(a) in a case where the territory is a territory with the government of which arrangements having the force of law by virtue of section 826(1) have been made, the entity is regarded as being a resident of that territory under those arrangements, and

(2) In this Chapter, “listed territory” has the same meaning as in section 835YA subject to the modification that references to “an accounting period beginning” shall be read as references to “the making of a payment or distribution”.

“tax period” has the same meaning as it has in section 835Z;