3 December 2024 CTF Roundtable, Q.3

Policy Tabs

Summaries

Summary Under

B2B reporting engaged where loan from immediate NR parent (funded in turn in part with debt from ultimate parent) bears reduced (10%) withholding

References in NT 2023-05 to a designated transaction include:

[S]ubsections 212(3.1) to (3.3) help to ensure that withholding tax under Part XIII...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

s. 212(3.1) generally inapplicable where immediate funder receives only common shares financing from ultimate funder

The list of notifiable transactions for purposes of s. 237.4(3) essentially includes a non-resident person (NR1) entering into an arrangement to...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.