Andrew Spiro Casey Richardson-Scott Canada's Income Tax Act (the ITA) contains an anti-avoidance rule (commonly referred to as the back-to-back loan rule) that generally prevents the use of arm's length or treaty-resident intermediaries to reduce non-resident withholding tax applicable to related-party interest payments. As part of an expansion of these rules to various different circumstances, the 2016 federal Budget, released on March 22 2016, proposes to extend the back-to-back loan rules to cross-border rents and royalties.
May 26 2016