This table summarizes treaty withholding tax rates on dividend payments arising in Canada. The lower rate applies where the recipient is a company that owns or controls a specific interest of the payer:
Notes:
(1) United States:
According to the Canada-US tax treaty, the term "dividends" as used means income from shares or other rights, not being debt-claims, participating in profits, as well as income subject to the same taxation treatment as income from shares by the taxation laws of the State of which the company making the distribution is a resident.
The 5 percent of the gross amount of the dividends is applicable if the beneficial owner is a company that owns at least 10 percent of the voting stock of the company paying the dividends;
15 percent of the gross amount of the dividends in all other cases.
(2) Netherlands:
5 percent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) that owns at least 25 percent of the capital of, or that controls directly and indirectly at least 10 percent of the voting power in, the company paying the dividends;
notwithstanding subparagraph (a), 10 percent of the gross amount of the dividends, if the dividends are paid by a non-resident-owned investment corporation that is a resident of Canada to a beneficial owner that is a company (other than a partnership) that is a resident of the Netherlands and that, owns at least 25 percent of the capital of, or that controls directly or indirectly at least 10 percent of the voting power in, the company paying the dividends; and
15 percent of the gross amount of the dividends in all other cases.
(3) Hong Kong:
5 percent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) that controls directly or indirectly at least 10 percent of the voting power in the company paying the dividends; and
15 percent of the gross amount of the dividends, in all other cases.
(4) China, P.R. (Not Hong Kong):
10 percent of the gross amount of the dividends if the beneficial owner is a company that owns at least 10 percent of the voting stock of the company paying the dividends;
15 percent of the gross amount of the dividends in all other cases.
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