23U.K.Where a foreign income dividend paid by a company before 6th April 1999—
(a)is received by a person on or after that date, and
(b)is not one in relation to which section 246D of the Taxes Act 1988 applies,
the recipient shall be treated, for all purposes of the Tax Acts, as receiving instead a qualifying distribution made by a company resident in the United Kingdom of an amount equal to nine tenths of the amount of the foreign income dividend.