Words and Phrases - "income or profits tax"
5 October 2012 Roundtable, 2012-0451251C6 F - Excess of foreign tax withheld at source
Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Taxforeign withholdings on American depositary receipts in excess of Treaty-limited rate does not qualify as an income tax
Tax is systematically withheld on income from ADRs at above the maximum rates permitted by the conventions. Can such withholdings be considered...
Words and Phrases
income or profits taxLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | tax withheld in excess of Treaty-rate is not deductible as an expense | 69 |