How will cross-border loans benefit from the elimination of withholding tax on arms length interest payments?
Under the former rules, most non-Canadian lenders were able to lend to Canadians free of withholding tax only if the borrower and loan satisfied a number of restrictive conditions. Under the new regime, the availability of the exemption does not depend on the status of the borrower or the terms of the loan (so long as it does not provide for participating interest or relate to certain types of convertible debt).
Related Questions
- Will withholding tax be eliminated on interest paid between parties who are related or otherwise do not deal at arms length?
- How will cross-border loans benefit from the elimination of withholding tax on arms length interest payments?
- Is the elimination of withholding tax on arms length (unrelated party) interest retroactive?
