Translation of "dividende de participation " (French → English) :

(b) where it can reasonably be considered that the principal purpose for an acquisition of a share of the capital stock of a corporation (in this paragraph referred to as the “issuer”) by any person (in this paragraph referred to as the “acquirer”) who had, immediately after the time of the acquisition, a substantial interest in the issuer from another person who did not, immediately before that time, have a substantial interest in the issuer, was to avoid or limit the application of Part I or IV. 1 or this Part with respect to a dividend on the share, the a ...[+++]cquirer and specified persons (within the meaning assigned by paragraph (h) of the definition “taxable preferred share” in subsection 248(1)) in relation to the acquirer shall be deemed not to have a substantial interest in the issuer with respect to any dividend paid on the share;

5. Where a company which is a resident of a Party derives profits or income from the other Party, that other Party may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other Party or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other Party, nor subject the company’s undistributed profits to a tax on the company’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Party.

5. Where a company which is a resident of a Contracting State and not also a resident of the other Contracting State derives profits or income from the other State, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in that other State, nor subject the company’s undistributed profits to a tax on the company’s undistributed profits, even if the dividends paid or the undistributed profits co ...[+++]nsist wholly or partly of profits or income arising in such other State.

Article 21 lays down the conditions under which dividends and incomes from a foreign company are tax exempt when received by a company which is tax domiciled in Spain.

The amendments are the following: allow a first-time adopter in its separate financial statements to use as the deemed cost of an investment in a subsidiary, jointly controlled entity or associate either the fair value at the entity's date of transition to IFRSs or the previous GAAP carrying amount of the investment at that date; delete from IAS 27 the definition of the ‘cost method’, with the result that an investor is required to recognise as income in its separate financial statements all dividends received from a subsidiary, jointly controlled entity or associate, even if the dividend is paid out of pre-acquisition reserves; clarif ...[+++]y how to determine the cost of an investment under IAS 27 when a parent company reorganises the operating structure of its group by establishing a new entity as its parent and this new parent obtains control of the original parent by issuing equity instruments in exchange for existing equity instruments of the original parent.

The result is that the fairness reports would have to be provided, with copies sent to OSFI, on the fairness to participating policyholders of the policy for determining policyholder dividends and bonuses to participating policyholders, and at least annually, on the continuing fairness of those policies; on the fairness to participating policyholders of the policy respecting the management of the participating account, and at leas ...[+++]t annually, on the continuing fairness of those policies; on the fairness to adjustable policyholders of criteria for making changes to adjustable policies, and at least annually, on the continuing fairness of those policies; on the fairness to participating policyholders of any proposed dividend to participating policyholders; and finally, that any changes made by the company with respect to adjustable policies during the year were made in accordance with the applicable policy and that such changes were fair to adjustable policyholders.