Article 10

look-through approach to applying treaties to dividends paid by Canco to a partnership between a German and US partner

a securities loan between residents of two Treaty countries did not change the beneficial ownership of the transferred shares

dividend which was on-paid immediately nonetheless benefited from the Trinidad-Barbados Treaty exemption

application of PPT where Treaty-resident pure holdco with ultimate Treaty-resident parent received Canco dividends

marginally increasing a shareholding to access the Treaty-reduced rate likely would not engage the PPT

different treatment of losses under Pt. XIV and Art. X(6) of the Canada-US Treaty and of investment allowance

capital for purposes of determining a Canadian Treaty-reduced dividend withholding rate of 5% references stated capital

engaging the “one of the main purposes” test in Art. 10(8) of the Canada-UK Treaty for accessing reduced withholding resulted in a 25% withholding rate

Swiss collective investment vehicle treated as flow-through for purposes of the pension/ retirement fund dividend exemption in the Canada-Swiss treaty

subsequent refund to Canadian shareholder of French avoir fiscal treated as a dividend payment for dividend withholding purposes