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Characterisation for treaty purposes of manufactured dividends received in terms of securities lending arrangements

Equity securities lending arrangements are contracts whereby a shareholder lends his shares to a borrower for a period of time. If dividends are declared during that period, these accrue to the borrower, and the borrower pays a manufactured dividend to the lender as compensation. The applicable inco...

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Bibliographic Details
Main Author:	Vanlierde, Angela
Other Authors:	West, Craig
Format:	Thesis
Language:	English
Published:	Department of Finance and Tax 2021
Subjects:	International Taxation
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