No. 21. Income Tax. 1967.

 Provided that where tax is not paid or payable by the
 company on the whole income out of which the dividend is paid,
 the deduction shall be restricted to that portion of the dividend
 which is paid out of income on which tax is paid or payable by
 the company.
 (2) Every such company shall, upon payment of a divi-
 dend, whether tax is deducted therefrom or not, furnish each
 shareholder with a certificate setting forth the amount of the
 dividend paid to the shareholder and the amount of tax which
 the company has deducted or is entitled to deduct in respect
 of that dividend and also, where the tax paid or payable by
 the company is affected by double taxation relief, the rate
 (hereinafter in this Ordinance referred to as the nett local rate)
 of the tax paid or payable by the company after taking double
 taxation relief into account.
 (3) In this section the expression "double taxation
 relief" means any credit for foreign income tax which is allow-
 able against tax chargeable under this Ordinance by virtue of
 arrangements having effect under section 91 and any relief
 allowable undey sections 90 and 92 including any credit or relief
 which has been taken into account in determining the nett local
 rate applicable to any dividends received by the company.
 (4) This section shall, mutatis mutandis, apply to a
 Trustee under section 19 (2).

 39. (1) Any tax which a company has deducted or is entitled tax deducted.
 to deduct under the last preceding section from a dividend paid
 to a shareholder, and any tax applicable to the share to which
 any person is entitled in the income of a body of persons assessed
 under this Ordinance, shall, when such dividend or share is
 included in the chargeable income of such shareholder or person,
 be set off fof the purposes of collection against the tax charged
 on that chargeable income.
 Provided that where no tax has been deducted from the
 dividend such dividend must be deemed to have been paid out
 of the net profits of the company after tax has been paid, and
 must therefore be grossed to such a figure as, after deduction
 of tax at the prescribed rate, will amount to the actual dividend
 paid, the shareholder being given credit for the difference as
 tax paid in respect of dividend, and liable to return the gross
 sum as income in his return.
 (2) This section shall, mutatis mutandis, apply to a
--Trustee and beneficiaries under Section 19 (2).