(1)
Nigerian dividends include —
(a)
dividend distributed by a Nigerian company, and shall be the gross amount of that dividend before any deduction ; and
(b)
any amount of the undistributed profit of a Nigerian company, which is treated as distributed under the provisions of any law in Nigeria.
(2)
The income from a dividend distributed by a Nigerian company is deemed to arise on the day on which payment of that dividend becomes due.