Canadian equities - Quick refund - eligibility, documentation, deadlines
Eligible beneficial owners
Beneficial owners are eligible for a quick refund of withholding tax on income from Canadian equities as follows:
| Eligible beneficial owners | Rate applicable at source |
| Resident of a DTT country (non-resident according to Form NR301) a | Tax treaty or 25%, whichever is lower |
Tax-exempt entities | 0% |
a. Partnerships (NR302) and Hybrid Entities (NR303) are not considered eligible and must submit any reclaim applications via the standard refund procedure.
Residents of a DTT country - non-resident according to Form NR301 (General)
Quick refund is available for beneficial owners who qualify for the benefit of a reduced rate of withholding tax in accordance with a DTT between their country of residence and Canada and who qualify as non-residents according to Form NR301. The maximum rate of withholding tax is defined in the relevant DTT.
Tax-exempt entities
Quick refund is available for beneficial owners who are recognised as tax-exempt by the Canada Revenue Agency.
In both cases, if the eligible beneficial owner has not obtained relief at source or applied for a quick refund, a reclaim of the relevant amount of withholding tax is available through Clearstream Banking, via standard refund, by submitting the appropriate documentation.
Important note:
Customers acting as Swiss intermediary for final beneficial owners of Canadian equities can also apply for a quick refund via Clearstream Banking.
Documentation requirements
For a quick refund of withholding tax on income from Canadian equities, the documentation requirements vary according to the type of eligible beneficial owner, as follows:
For Residents of a DTT country who qualify as non-resident according to Form NR301:
- One-Time Certificate – Canadian Equities and Trust Instruments;
- Per-Payment instruction;
- CRA Form NR301, as follows:
- For customers holding proprietary assets: An original Form NR301, signed by the customer as final beneficial owner qualifying for DTT relief according to Form NR301, must be submitted to Clearstream Banking directly.
- For customers acting as intermediary: An original Form NR301, signed by the final beneficial owner qualifying for DTT relief according to Form NR301, must be submitted to and retained by the customer, who must provide it promptly to Clearstream Banking upon request at any time.
The customer must exercise due diligence with respect to the information provided on this form and must verify whether the information is sufficient to claim DTT relief on behalf of the final beneficial owner.
and, in addition, for pension plans that are exempt by virtue of a DTT:
- A letter from the pension plan declaring that it is operated exclusively to provide pension or retirement benefits and that it qualifies for exemption on dividend income under the specified article of the relevant country treaty with Canada; and
- A letter from the local tax authority confirming the tax status of the pension or retirement plan.
and, upon request:
- List of Beneficial Owners – Canadian Securities;
- CRA Form NR301 (from customers acting as intermediary);
- Certificate of Residence;
- Any other tax documentation as required from time to time.
For Tax-exempt entities:
- One-Time Certificate – Canadian Equities and Trust Instruments;
- Per-Payment instruction;
- A Withholding Tax Exemption Letter issued by the CRA (including the “tax-exempt registration number").
Swiss Intermediary banks:
- One-Time Certificate – Canadian Equities and Trust Instruments - Swiss Intermediary;
- Per-Payment instruction.
Deadline for receipt of documents
The deadline for the receipt of required documentation in support of a reclaim of withholding tax on Canadian Securities using the quick refund procedure through Clearstream Banking will be communicated to customers via announcements, on an annual basis, at the year end. Customers must therefore refer to the annual announcement in order to have the applicable deadlines.
The usual deadlines are however as defined below:
Event payment date | Clearstream Banking deadline |
From 1 January to 30 November | 2 December, 10:00 CET of the year of the dividend payment. |
From 1 December to 31 December | 30 December, 10:00 CET of the year of the dividend payment. |
Positions for which customers have not submitted the requested documentation before the prescribed deadline will be taxed, through Clearstream Banking, at the maximum applicable rate.