22(1)Where, in the case of an accounting period of a company beginning before 6th April 1999 and ending on or after 5th April 1999 (“a transitional period”), there would (apart from this sub-paragraph) be such an excess as is mentioned in section 246F(3) of the Taxes Act 1988, no such excess shall be deemed to have arisen.
(2)In their application in relation to foreign income dividends paid in an accounting period of a company beginning before 6th April 1999, sections 246J(5) and 246K(10) of the Taxes Act 1988 shall have effect as if the reference to any subsequent accounting period—
(a)included an accounting period which immediately follows a transitional period, but
(b)did not include any later accounting period.
23Where 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.