“dividend” includes—

(a) any distribution by a company of accumulated profits, whether capitalized or not, if such distribution entails the release by the company to its shareholders of all or any part of its assets or reserves;

(b) any distribution by a company, to the extent to which the company possesses accumulated profits, whether capitalized or not, to its shareholders of debentures, debenture-stock or deposit certificates in any form;

(c) any distribution made to the shareholders of a company on its liquidation to the extent to which the distribution is attributable to the accumulated profits of the company immediately before its liquidation, whether capitalized or not;

(d) any distribution by a company to its shareholders on the reduction of its capital, to the extent to which the company possesses accumulated profits, whether such accumulated profits have been capitalized or not;

(e) any profit remitted outside Bangladesh by a company not incorporated in Bangladesh under the Companies Act, 1994 (Act no. XVIII of 1994);

(f) any distribution of profit of a mutual fund, real estate investment trust, exchange traded fund or an alternative investment fund;

(g) any payment by a ¹[***] company of any sum, whether as representing a part of the assets of the company or otherwise, by way of advance or loan to shareholders, or any payment by any such company on behalf, or for the individual benefit, of any such shareholder, to the extent to which the company, in either case, possesses accumulated profit;

but does not include—

(i) a distribution made in accordance with sub-clause (c) or sub-clause (d) in respect of any share including preference share for full cash consideration, or redemption of debentures or debenture stock, where the holder of the share or debenture is not entitled in the event of liquidation to participate in the surplus assets;

(ii) any advance or loan made to a shareholder in the ordinary course of its business, where the lending of money is a substantial part of the business of the company;

(iii) any dividend paid by a company which is set off by the company against the whole or any part of any sum previously paid by it and treated as dividend within the meaning of ²[sub clause (g)] to the extent to which it is so set off;

(iv) any bonus share issued by a company;

Explanation.—The expression “accumulated profits” shall include—

(a) in this clause, any reserve made up wholly or partly of any allowance, deduction or exemption admissible under this Act;

(b) in case of sub-clauses (a), (b) and (d), all profits of the company up to the date of such distribution; and

(c) in case of sub-clause (c), all profits of the company up to the date of its liquidation;