Entities providing and receiving the benefit



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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