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: | Dissertation |
Language: | English |
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Faculty of Commerce
2021
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Online Access: | http://hdl.handle.net/11427/32781 |