Minimum holding period requirement for dividend treaty benefits conditions entitlement and allows reservations with notification obligations. Dividend treaty relief for resident companies is conditioned on the beneficiary maintaining the requisite ownership threshold throughout a continuous 365 day period including the payment date; ownership changes directly resulting from corporate reorganisations are excluded from that computation. Parties may reserve application of the Article wholly or where treaties already contain a minimum holding period (shorter or longer), and must notify the Depositary of qualifying treaty provisions; the Article's ownership period requirement becomes applicable to a provision only after all Contracting Jurisdictions have submitted the required notification.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Minimum holding period requirement for dividend treaty benefits conditions entitlement and allows reservations with notification obligations.
Dividend treaty relief for resident companies is conditioned on the beneficiary maintaining the requisite ownership threshold throughout a continuous 365 day period including the payment date; ownership changes directly resulting from corporate reorganisations are excluded from that computation. Parties may reserve application of the Article wholly or where treaties already contain a minimum holding period (shorter or longer), and must notify the Depositary of qualifying treaty provisions; the Article's ownership period requirement becomes applicable to a provision only after all Contracting Jurisdictions have submitted the required notification.
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