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Versions of s. 18.4(12)(d)(ii)(A)

I-3.3 — Income Tax Act · 1 version · View current text

Historical text comes from the Justice Laws point-in-time corpus and is unofficial — not the official version.

  1. 2024-06-20 to present available View Source

    the tax laws of one country treat one or more transactions included in the transfer arrangement, either alone or together, as or as equivalent to a borrowing or other indebtedness, or treat all or a portion of the payment as arising under, or in connection with, a borrowing or other indebtedness, and the tax laws of another country do not treat the transaction or transactions, or the payment, as the case may be, in that manner, or