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  • Entities providing and receiving the benefit



    This information may not apply to the current year. Check the content carefully to ensure it is applicable to your circumstances.

    End of attention

    For a benefit to be treated as a deemed dividend, the benefit must be provided by the CFC to a shareholder or an associate of a shareholder.

    The benefit must be provided by either:

    • an unlisted country CFC, or
    • another entity under an arrangement with the CFC, where the CFC has transferred property or services in consideration for the benefit to:
      • the other entity, or
      • any other entity.

    These transfers of property or services are referred to as arrangement transfers.

    Last modified: 05 Dec 2006QC 17522