Versions of s. 212(22)
-
If this subsection applies at any time in respect of a taxpayer, then for the purpose of paragraph (1)(b), the taxpayer is deemed, at that time, to pay interest to the non-arm’s length creditor, the amount of which is determined by the formula A × (B − C) ÷ B where A is the particular amount referred to in paragraph (21)(a); B is the rate of tax that would be imposed under this Part in respect of the particular amount if the particular amount were paid by the taxpayer to the non-arm’s length creditor rather than the interest coupon holder at that time; and C is the rate of tax imposed under this Part in respect of the particular amount paid or credited to the interest coupon holder at that time.