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Prévost Car: Dutch Intermediary is "Beneficial Owner" Under Treaty |
October 12, 2009
Previously published on March 2009
In The Queen v. Prévost Car Inc., the Federal Court of Appeal dismissed the Minister of National Revenue's appeal from the Tax Court's decision that the Canadian corporate taxpayer's parent, a Dutch holding company, was the "beneficial owner" of dividends which entitled it to a reduction in the 25% rate of Canadian non-resident withholding tax to 5% under Article 10(2) of the Canada-Netherlands Income Tax Convention (the "Treaty").
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The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance. |
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