Article 10

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

recipient of dividends on borrowed shares was not their beneficial owner because of requirement to pay dividend compensation payments

Canadian mutual fund trust or pension fund trust deemed to be the beneficial owner of dividends by Art. 29(7)(a) of the Canada-France Convention

violating main purpose test in HK Treaty increases dividend rate/ PPT object and purpose test not violated by using personal holding company in same jurisdiction