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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