DT4607 – Canada: Interest
Article 11(9) provides that interest paid by a United Kingdom
company in circumstances in which ICTA88/S209 (2)(d) would
otherwise apply is not to be treated as a distribution unless the
Canadian resident company is one in which more than 50 per cent of
the voting power is controlled, directly or indirectly, by United
Kingdom residents. See also INTM153120.
