If tax payable by a person ("P") as a result of section 3 is paid by—
the company ("C") to which the gain accrues, or
a company by reference to which P is regarded as an indirect participator in C,
the amount paid is not a payment to P for tax purposes.
The reference here to tax purposes is to the purposes of income tax, capital gains tax or corporation tax.
For the purposes of section 3 the amount of a gain or loss accruing to a company is calculated as if the company were a company resident in the United Kingdom chargeable to corporation tax on the gain.