Section 6: Withholding tax on interests, dividends, etc.

(1) Interests or any other amounts payable or paid to any company other than a Nigerian company in respect of any loans or other financial arrangements made with the Company shall be exempt from taxation in Nigeria.
(2)
Dividends paid out of the account kept by the Company for the purposes of section 17 (1) of the Industrial Development (Income Tax Relief Act) 1971, whenever declared or paid, shall be deemed to be paid out of profits exempted from tax and the proviso to section 18 of the Companies Income Tax Act 1979 shall apply accordingly.
(3) In so far as any payments are made by the Company in respect of interest or other payments within subsection (1) of this section, dividends within subsection (2) of this section and payments within subsection (4) of this section, the provisions of section 78, 79, 80, and 81 of the Companies Income Tax Act 1979, including any provisions made pursuant to those sections, shall not apply.
(4)
Notwithstanding the provisions of subsection (2) of this section, dividends declared out of profit not credited to the special account under the provisions of section 17 of the Industrial Development (Income Tax Relief) Act, shall be subject to the normal rules on withholding tax.
(5) In respect of any work or services provided from outside Nigeria to the Company by any person other than a Nigerian company or citizen, that person shall be exempt from tax on income or profits arising from the provision of that work or those services.
(6)
Any transfer of shares or any other interest in the Company, or any company connected with the Company, shall be deemed, for the purposes of the Capital Gains Tax Act 1967, to take place for such consideration as would leave the transferor with neither a gain nor a loss under section 12 of that Act, if the transferor and transferee are connected within the meaning of section 23 of the same Act.
(7) For the purpose of subsection (6) of this section, legal proof of the relationship between the transferor and any transferee shall be clearly established.
(8)
Where any shipping company owned directly or indirectly by the Company or one or more of the shareholders of the Company carries on the business of transport by sea of liquefied natural gas produced by the Company, such shipping company shall be exempt from tax in Nigeria under section 14 of the Companies Income Tax Act, or any other law, on the profits derived from that business.
[1993 No. 113.]
(9)
In respect of any payment made by the Company to a shipping company within subsection (8) of this section for the shipment of liquefied natural gas, by way of hire, freight, demurrage or otherwise, the Company shall be exempt from the requirement to withhold tax or any other impost from the payment, under section 78 of the Companies Income Tax Act, or any other law.
(10)
The provisions of the National Shipping Policy Act and the regulations made thereunder shall not be applicable to the Company, its contractors, sub-contractors, its customers or a shipping company referred to in subsection (8) of this section.
[1993 No. I 13.]