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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
(0 Comments)

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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