3. Withholding taxes
(1) The rate of dividends tax contemplated in section 64E that is paid by an oil and gas company on the amount of any dividend derived from oil and gas income must not exceed zero per cent of the amount of that dividend.
(2) Notwithstanding subparagraph (1), the rate of dividends tax may not exceed 0 per cent of the amount of any dividend, as defined in section 64D, that is paid by any oil and gas company out of amounts attributable to its oil and gas income if all of its oil and gas rights are solely derived (directly or indirectly) by virtue of an OP26 right as defined in Schedule II of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002), previously held by that company.