International cases

International cases

CIR v Namsov Fishing Enterprises (Pty) Ltd
(1 Comments - Last one made: Wednesday, October 17, 2012 10:35 PM)

In this case before the Supreme Court of Namibia, the meaning of the phrase "supplies of entertainment in the ordinary course of such business” was considered.

Prevost Car Inc. v Her Majesty the Queen

This the first case where the Court of Canada addressed the meaning of "beneficial ownership” for purposes of Canada’s tax treaties. The court decided that a Dutch holding company that received dividends from a Canadian subsidiary was the beneficial owner of the dividends and thus entitled to the lower rate of withholding tax provided by the Canada-Netherlands tax treaty.

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