Beneficial owners recognised for tax purposes – Canada

04.01.2024

The following types of beneficial owner are recognised for tax purposes in Canada:

Debt securities

Beneficial owner

Tax rate

All (No withholding tax is deducted on interest from Canadian debt securities held in Clearstream Banking)

The only exceptions are in the event that a debt security distributes taxable dividends and in the very rare cases of related non-residents not dealing “at arm’s length” with the issuer and for Participating Interest, in which cases 25% withholding tax is applicable and may be applied upon request from the client.

0%

Equities

Beneficial owner

Tax rate

Residents of a Double Taxation Treaty (DTT) country who qualify as non-resident according to Form NR301 (General)

DTT

Resident of a DTT country who qualify as non-resident according to Form NR302a (Partnerships)

DTT

Resident of a DTT country who qualify as non-resident according to Form NR303a (Hybrid entities)

DTT

Non-resident tax-exempt entities

0%

Canadian residents

25%

a. Partnerships (Form NR302) and Hybrid entities (Form NR303) are not considered eligible and must apply to reclaim withholding tax via the standard refund procedure instead.

Trust instruments

Beneficial owner

Tax rate

Residents of a Double Taxation Treaty (DTT) country who qualify as non-resident according to Form NR301 (General)

DTT

Resident of a DTT country who qualify as non-resident according to Form NR302a (Partnerships)

DTT

Resident of a DTT country who qualify as non-resident according to Form NR303a (Hybrid entities)

DTT

Non-resident tax-exempt entities

0%

Canadian residents

25%

a. Partnerships (Form NR302) and Hybrid entities (Form NR303) are not considered eligible and must apply to reclaim withholding tax via the standard refund procedure instead.