(1) Where the income includes dividends, and in case of such dividends under the agreement, it necessary to consider any foreign tax (directly claimable or whether deductible on the basis of dividends or not) for the purpose of determining whether any rebate shall be allowed against Bangladesh tax or the amount of rebate payable, then the relevant income shall be deemed to have been increased by an equivalent portion of the foreign tax related to the dividends considered for the purpose of determining the amount of rebate.

(2) Where, under sub-section (1), an amount of income is deemed to have been increased, the foreign tax paid on the dividend paid at any particular time by the statutory body paying the dividend, unless foreign tax, directly or by way of deduction, is chargeable or if the said dividend is not paid within the prescribed period, the dividend paid at the time of preparation of the last
accounts completed by the said statutory body before the dividend is payable shall be taken into consideration.

Explanation.—For the purposes of this sub-section, “paid” shall be deemed to be paid, deposited or distributed or to have been paid, deposited or distributed.

(3) Notwithstanding anything contained in the preceding provisions of this section and in section 55, if any portion of foreign tax on any source of income is not allowed a rebate against Bangladesh tax, the amount of such income shall be deemed to be reduced by an amount equal to the portion of such foreign tax.

(4) Where any income tax is payable on the basis of money received from Bangladesh, in that case the amount of the said money shall be deemed to have increased by the amount of allowance allowed as concession against income tax.

(5) The provisions of sub-sections (1) and (3) of this section shall not apply in computing the total income of a person for the purpose of determining the rate referred to in sub-section (3) of 247, and in accordance with sub-section (4) of this section ”allowable against income-tax’ concessional benefit” shall be substituted by ”foreign tax paid at source of income”.