Beneficial owners recognised for tax purposes - Canada

The following types of beneficial owners are recognised for tax purposes in Canada:

Trust instruments
Beneficial owner	Tax Rate
Residents of a Double Taxation Treaty (DTT) country who qualify as non-resident according to Form NR301 (General)	DTT
Resident of a DTT country who qualify as non-resident according to Form NR302^a (Partnerships)	DTT
Resident of a DTT country who qualify as non-resident according to Form NR303^a (Hybrid entities)	DTT
Tax-exempt entities a	0%

a. Tax exempt entities, Partnerships (Form NR302) and Hybrid entities (Form NR303) are not considered eligible for a relief at source or quick refund and must apply to reclaim withholding tax via the standard refund procedure instead.

Residents of Canada

As of 1 January 2012, clients must refrain from holding, on their Clearstream Fund Centre account, Vestima fund securities on behalf of beneficial owners (including themselves, if applicable) who are resident for tax purposes in Canada as defined by relevant Canadian laws and regulations. Such beneficial owners are not eligible for any relief at source or reclaim of withholding tax on income from Canadian Vestima fund securities via Clearstream Fund Centre.

Please refer to the Holding restriction - Investment Funds - Canada section.

Beneficial owners recognised for tax purposes - Canada - CFCL