n Without Prejudice - The saga of exempt dividends : tax

Volume 12, Issue 3
  • ISSN : 1681-178X



S8E of the Income Tax Act introduced anti-avoidance provisions relating to, , preference share financing arrangements. This section operates to deem dividends received by or accrued to the holder as interest in the hands of the holder. The application of s8E results in the shareholder being subject to tax on the interest. The distribution is, however, still treated as a dividend for the issuer.

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