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(a) Dividends

42. As a rule, dividends on shares of a company incorporated in N.E.I. are not taxable when received by non-resident individuals, partnerships or companies. They may be taxed only when considered business income. For example, when a non-resident enterprise carries on a business in N.E.I. and invests its reserve funds or surplus cash temporarily in shares of any company, N.E.I. or foreign, the dividends are considered to be a part of the business income of the establishment in N.E.I., and are therefore taxable as such.

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