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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: 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.