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- Title
Prévost Car Inc. v. The Queen.
- Authors
Morris, Ryan L.
- Abstract
The article discusses a court case in which the Federal Court of Appeal in Canada upheld the ruling of the Tax Court regarding the tax implications of the concept of beneficial owner of dividends. In Prévost Car Inc. versus the Queen, Prévost Car Inc. withheld a tax on the dividends of its shareholder Prévost Holding B.V. to claim a reduction in withholding rate pursuant to the Canada-Netherlands income tax treaty. The federal court considered the model tax treaty of the Organisation for Economic Co-operation and Development (OECD).
- Subjects
CANADA; ACTIONS &; defenses (Law); TAXATION of dividends; TAX withholding laws; DOUBLE tax agreements; PREVOST Car Inc.; ORGANISATION for Economic Co-operation &; Development; CANADA. Federal Court of Appeals; TAX laws
- Publication
Canadian Tax Journal / Revue Fiscale Canadienne, 2009, Vol 57, Issue 2, p307
- ISSN
0008-5111
- Publication type
Article