s 23 Certain dividends exempted from income tax
(1) As soon as any amount of income of a pioneer company has become exempted under section 22, that amount shall be credited to an account to be kept by the pioneer company for the purposes of this section (that account and company being in this section and section 24 referred to as the exempt account and the relevant company respectively). (2) Where the exempt account is in credit at the date on which any dividends are paid by the relevant company out of income which has been exempted under section 22, an amount equal to those dividends or that credit, whichever is the lesser, shall be debited to the exempt account. (3) So much of the amount of any dividends debited to the exempt account under subsection (2) as is received by a shareholder in the relevant company shall, if the Director General is satisfied with the entries in the exempt account, be exempt from tax under the principal Act in the hands of that shareholder. (4) Any dividends debited to the exempt account under subsection (2) shall be treated as having been distributed to the shareholders (or any particular class of shareholders) of the relevant company in the same proportions as those in which the shareholders in question were entitled to payment of the dividends giving rise to the debit. (5) Until the Director General is satisfied that there is no further need to maintain the exempt account, the relevant company shall deliver to the Director General a copy of the exempt account made up to a date specified by him whenever it is called upon to do so by notice in writing sent by the Director General to the company's registered office. (6) Where— (a) an amount is received by way of dividend from the relevant company by a shareholder; (b) that amount is exempt from tax under the foregoing subsections; and (c) that shareholder is a company, any dividends paid by that shareholding company to its shareholders shall, to the extent that the Director General is satisfied that the dividends so paid are paid out of that amount, be exempt from tax in the hands of those shareholders. (7) Section 108 of the principal Act shall not apply in respect of any dividend or part thereof which is debited to the exempt account or in respect of any dividend or part thereof which is exempt under subsection (6).