15 May 2024 IFA Roundtable, Q.1

Policy Tabs

Summaries

Summary Under

a non-resident’s increasing its voting shareholding in Canco to access the Treaty-reduced dividend withholding rate likely does not engage the PPT

2019-0792651I7 concluded that Art. 10(8) of the Canada-UK Treaty would deny the Treaty dividend withholding tax rate reduction where a UK-resident...

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Summary Under

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

A UK-resident corporation increased its voting shareholding of Canco the day before a dividend was paid so as to hold 10% of the shares. How would...

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