If a company declares a dividend to a trust who is repaying a loan that it had to take out in order to buy the shares in this company do they need to deduct withholding tax?

And just to rephrase so I come across clearly
One of the shareholders of this company is a trust. the individual decided to keep the shares in her trust. but the trust/individual had to take out a loan so that it can buy the shares in this company.
The company is now declaring a dividend and I would like to know whether the company is liable to withholding 15% dividend tax or is this exempted from Dividend tax?


Thank you