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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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| Format: | Thesis |
| Language: | English |
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Department of Finance and Tax
2021
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