IT-155R3 "Exemption from Non-resident Tax on Interest Payable on Certain Bonds, Debentures, Notes, Hypothecs or Similar Obligations"

The exemption in s. 212(1)(b)(ii)(C) is not applicable to refund interest.

General discussion of s. 212(1)(b)(ii)(C) exemption for governmental obligations.

An amount paid by a guarantor in respect of interest payable under a guaranteed obligation is subject to the withholding tax unless the obligation...

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