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Variable interest on loans: Tax treaty characterization as dividends (Art. 10) or interest (Art. 11)?

March 31 2023

Open Access Video

This is the first video on the special video discussion series on Art. 10 (dividends) of the tax treaties.

Other Episodes in the Art. 10 (Dividends) Series:

Could notional interest be treated as disguised dividend?

Could an indirect shareholder be considered as a shareholder for the purpose of a tax treaty? 

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